Restricted Party Screening
Overview
Restricted Party Screening (RPS) is required to ensure that the University’s activities do not violate end user/diversion controls and OFAC sanctions based on the lists of prohibited parties (entities, persons, organizations) which U.S. Government agencies publish in the Federal Register on an ongoing basis.
There are numerous lists that must be checked, found at the following link:
Guidance on end-user and end-use controls and U.S. person controls
The University licenses the Descartes Visual Compliance software tool to perform RPS. Individual and entities belonging to the following categories (at a minimum) should be screened:
- International vendors and service providers (including scientific instrument purveyors and related support services)
- International commercialization partners
- International industry partners (sponsored research/other)
- Visiting international delegations to science and engineering laboratories
- Industry users of Core Lab/Recharge Centers
- Consignees of international shipments
- J-1 Exchange Visitors prior to the University issuing a DS-2019 and employees on University-sponsored nonimmigrant visas prior to filing a Form I-129 with USCIS
- International donors
- International institutions that are flagged during the course of COI/COC reviews
- International institutions identified by faculty as sabbatical host institutions
- Parties to international academic teaming and collaboration agreements (outside of OSP); international MOUs/MOAs
- International Material Transfer Agreement partners (receiving/sending)
- International instrument surplus disposition: recipient persons/entities
- International entities located in foreign countries of concern that are part of proposed international travel itineraries.
RPS is coordinated by the RSO or by designated personnel trained to perform the screening function, including OGC, Office of Sponsored Projects, and the Technology Licensing Office (“TLO”). In the event of a potential RPS match, the University shall determine whether there is an actual match and determine whether the proposed activity may go forward. In many cases, exports of any item Including EAR99 items to restricted parties or entities would constitute an enforceable export control violation.