Procedure Library

Restricted Party Screening

Purpose

The U.S. Department of the Treasury's Office of Foreign Assets Control (“OFAC”) administers and enforces U.S. economic sanctions. These laws restrict - or, in some cases, entirely prohibit - U.S. persons from engaging in transactions or “doing business with” certain designated individuals, entities, or countries.

A “U.S. person” (22 C.F.R. § 120.15; 15 C.F.R. § 772.1) includes:

1. U.S. citizens (born or naturalized)
2. Lawful permanent residents ( “green card” holders)
3. "Protected individuals" under 8 U.S.C. § 1324b(a)(3), including refugees and asylees
4. Corporations or other entities incorporated in the United States 

One of OFAC's key tools is the Specially Designated Nationals and Blocked Persons List (“SDN List”) - a continuously updated list identifying persons and entities associated with terrorism, narcotics trafficking, weapons proliferation, human rights violations, and sanctioned governments. 

Other U.S. agencies, such as the Department of Commerce, maintain additional lists that restrict certain exports or financial transactions or require prior authorization.

Applicability

As a U.S. entity, the University is legally obligated to comply with all U.S. sanctions and export control regulations. This includes ensuring that the University does not conduct business with individuals or organizations on the SDN List or other restricted-party lists. 

Non-compliance can result in significant civil and criminal penalties for both the University and individual employees.

About Screening

Restricted Party screening is the process of checking the name of individuals or entities involved in a proposed University activity -  research collaborations, procurement transactions, subawards, vendor relationships, donations, or any other form of engagement -  against the required U.S. government restricted-party lists.  

Screening before entering into any relationship helps prevent inadvertent violations.

Instructions

1. PI's and admins must contact OSP for restricted-party screening whenever a sponsored project proposes or involves:
   1. Individuals collaborating with non-US nationals in the U.S.
   2. Individuals collaborating with non-US nationals outside of the U.S.
   3. Subcontractors, vendors, donors, or partners who are non-U.S. nationals

The grid below details when screening is required:


NOTE: For collaborations not associated with a sponsored project, contact the Research Security Office directly to request screening.

Identifying When Export Controls or Sanctions May Apply

Export control or sanctions requirements may apply depending on:

• The subject matter or scope of work
• The nationality, location, or affiliations of the collaborators
• What the collaborators will do with the information, materials, or technology you share

icon We strongly recommend reviewing the Export Control Basics briefing to better understand these requirements.  

Activities that may require screening include:

• Professional or business exchanges with foreign countries or foreign nationals subject to U.S. government restrictions
•  Sending or receiving tangible items or technical data internationally
•  Sharing technical knowledge with foreign persons inside the United States (including employees and students
• International travel involving research equipment, data, or collaborations
• Work involving technologies with potential defense, earospace, or intelligence applications 

FAQ

Related Policies and Procedures

• Research Security, Export Control & Foreign Influence
• OSP Employee > Restricted Party Screening Procedures SOP