Export Control: Restricted Party Screening
Working with Restricted Entities
The U.S. government restricts collaborating with or shipping to certain individuals or organizations. Certain transactions with an individual, organization or entity appearing on any one of the U.S. government restricted party lists may be prohibited, require an export license or require further review. The University must not enter into subcontracts, exchange information, provide services, or otherwise participate, directly or indirectly, in any activities with any entity or person found on these lists without Export Control review.
The University uses Restricted Party Screening (RPS), escalation, and export license reviews to ensure compliance with federal export control regulations. A restricted party screening involves a review of these lists to ensure that the person or entity with whom you are interacting is not on one of these lists.
The University has a site license to software, Visual Compliance, which provides easy-to-use screening for denied parties. If you have not yet set up a Visual Compliance account to conduct your own screening or for instructions, see Using Visual Compliance for Restricted Party Screening.
When to Use Restricted Party Screening:
- Foreign collaborations
- Visitors, visiting scholars, or visiting graduate students
- Awards or agreements with foreign entities
- International shipments
- Paying foreign persons or entities (for purchases, travel, reimbursement, etc.)
Central and Departmental Administration should perform all necessary restricted party screenings and escalate matches to the Export Control Officer for review and determination of whether a license or technology control plan is needed or no action is required. For training, see Using Visual Compliance for Restricted Party Screening.
Before beginning a foreign collaboration, award, or agreement with a foreign entity, the Departments/Schools should perform a Restricted Party Screening on all collaborators (regardless of their citizenships and permanent resident statuses) as well as the collaborators’ affiliated institution.
To ensure that campus visitors are not listed on one of the federal Restricted Party Lists, Departments/Schools should perform a Restricted Party Screening on all visitors (regardless of their citizenships and permanent resident statuses) it will host, as well as the visitors’ affiliated institutions.
Before sending an international shipment, Departments/Schools should perform a Restricted Party Screening on all recipients (regardless of their citizenships and permanent resident statuses) as well as the recipients’ affiliated institution.
For visitors participating/collaborating in Research, please contact the Export Control Officer to review any issue that may arise. The Export Control Officer will review the visit and provide its recommendations. Please keep in mind that no export-controlled items, technical data and software can be disclosed or provided to visitors to our campus.
For assistance with RPS review, contact the Export Control Officer. The email should contain the following information:
- Name of individual to be screened.
- Name of affiliated organization (if applicable)
- Country of Nationality (for individuals) / Country of Incorporation (for organizations)
- Reason for conducting RPS (e.g., visiting scholar, H1B applicant, NDA)
- The PDF of the Visual Compliance results (if available)
The Export Control Officer will review RPS requests and escalations and determine if a license or technology control plan (TCP) is needed or if no further action is required.
If an export license is required it takes a minimum of six weeks to have it approved by the U.S. government and must be in place prior to the export.
Creation of a visitor’s agreement, TCP, or license may be required depending on the purpose of the visit, collaboration, or shipment.