Restricted party screening
Conducting restricted or denied party screening is a component of the University's export compliance program. The screening determines an individual or entity is named on a restricted, denied, debarred, designated, or blocked party list. If the individual or entity is named on one of these lists, you may be prohibited from doing business with or providing services to them.
The University uses Visual Compliance (licensed by eCustoms) software to screen individuals and other entities against mandatory "Restricted" and "Denied Parties" lists maintained by the U.S. government and allies, world organizations, and law enforcement agencies.
The following screenings are mandatory:
- Subawardees to sponsored projects (Sponsored Projects)
- Foreign non-governmental sponsors (Sponsored Projects)
- University-sponsored applicants on H1-B and J-1 Research Scholar, Professor, and Short-Term Scholar visas (Sponsored Projects)
- Foreign sponsors of international travel and international conferences (Sponsored Projects)
- All personnel and visitors associated with export-controlled research (Sponsored Projects)
- Foreign entities with whom the University has Confidentiality or Non-Disclosure Agreements (Sponsored Projects)
- Recipients of Materials Transfer Agreements (Sponsored Projects)
- Foreign vendors (Accounts Payable)
It is important to conduct a restricted party screening prior to shipping an item internationally and prior to doing business with, or providing services to, a foreign entity or individual. Export control and economic sanctions regulations may prohibit exports to certain end users even if the item to be exported is not controlled. Doing business with, providing services to, or exporting to individuals and entities named on restricted party lists is a violation of export control and economic sanctions regulations, and can be avoided by conducting a screening prior to the activity. To request a restricted party screening, contact Michele Dondanville at (775) 784-6360 or email@example.com.
What happens if there is a match?
When conducting a restricted party screenings, it is possible that matches will result. It is important to investigate all potential matches prior to taking action as there may be false matches or restrictions that do not apply to the planned activity. The following steps will be taken to investigate potential matches:
- Check the details in Visual Compliance, such as birthdate, passport number, address.
- If it is still unclear, contact the issuing government agency to discuss the potential match.
- If the match cannot be identified as being a false match, contact the Export Control Officer (ECO). The ECO will investigate further and, if necessary, contact the University's General Counsel to discuss further steps.
Until the status of a potential match has been confirmed, the planned activity or transaction with the entity in question must be put on hold.
If you have questions about restrict party screenings for export controls and economic sanctions regulation compliance, please contact Michele Dondanville, Export Control Officer, at (775) 784-6360 or firstname.lastname@example.org.