Procedure Library

Restricted Party Screening

Purpose

The U.S. Department of Treasury, Office of Foreign Assets Control (“OFAC”) enforces U.S. economic sanctions, which are laws and regulations that restrict and, in some cases, completely prohibit, U.S. persons (wherever located) from engaging in transactions or “doing business with” designated persons and entities. 

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

1. a U.S. citizen (whether born or naturalized);
2. a lawful permanent resident of the United States (e.g., “green card” holders); or
3. a protected individual as defined by 8 U.S.C. § 1324b(a)(3) (e.g., foreign persons such as refugees and asylees who are protected persons and considered U.S. persons for export control purposes). Corporations incorporated in the United States are U.S. persons for purposes of the ITAR and EAR.

In particular, OFAC publishes the Specially Designated Nationals and Blocked Persons List (“SDN List”), which is a constantly updated list that is part of a program of economic and trade sanction regulations targeting foreign countries and regimes, as well as individual bad actors, such as terrorists, or international narcotics traffickers. 

Several other U.S. federal agencies, such as the Department of Commerce, also maintain lists of persons and entities, where certain exports or financial transactions may be prohibited or require prior authorization.

Applicability

The University takes compliance with these economic sanctions and trade requirements seriously.  As a U.S. entity, the University is obligated to avoid ‘doing business’ with those who are found on the SDN List.  And, failure to comply with OFAC regulations can result in criminal and civil penalties for the University and its employees.

About Screening

“Screening” is the act of running the name of the person(s) and/or entity(s) with which you are engaging in a proposed research or academic activity, procurement or vendor transaction, sub-awardee relationship or any other “transaction” involving the person or their property, against the various “U.S. Lists to Check.” 

Screening a person or entity prior to engaging in an activity with them prevents the University from inadvertently engaging in a violation.

Instructions

1. PI's and admins should contact OSP re: screening for "Specially Designated Nationals" and other restricted parties whenever your projects propose or involve:
   1. Individuals who work with non-US nationals in the U.S.
   2. Individuals who work with non-US nations 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:
      
      
2. PI's and admins should identify whether export control or economic sanction regulations apply to your projects.
   
   This would typically depend upon the subject-matter focus of your activity, the persons with whom you are exchanging such subject matter, the countries that such persons are from or in, and/or what such persons are expected to do with the things or information that you share with them.
   
   

   icon We recommend that you explore the Export Control Basics briefing to learn more about export controls and economic sanctions.  

3. Activities that deserve export control/economic sanctions screening include:
   
   1. Entering into professional or business exchanges with, or on behalf of, countries or foreign citizens that have been singled out (by the U.S. Government)for special restrictions)
   2. Sending/receiving tangible items or technical information to/from foreign countries
   3. Sharing technical know-how with foreign persons in the United States (including employees and students)
   4. Traveling internationally
   5. Working with tangible items or information with actual or possible connections to defense, space or intelligence applications
4. Determining whether or not export control or economic  sanction regulations apply to your project/s typically depends on:
   1. The subject matter/statement of work;
   2. The persons with whom you are exchanging such subject matter, the countries that such person are from or in; and/or
   3. What such persons are expected to do with the things or information that you share with them.

FAQ

Related Policies and Procedures

• Policies > Research Security
• OSP Employee > Restricted Party Screening Procedures SOP