Restricted party screening
The U.S. government updates, maintains and enforces specific ‘restricted party lists’ that may be relevant to University of Rochester activities.
Here are a few restricted party lists that are particularly applicable to the University’s export compliance efforts:
- Specially Designated Nationals and Blocked Persons List (SDN)
- "Their assets are blocked and U.S. persons are generally prohibited from dealing with them."
- University of Rochester should not engage in any activities with an individual or entity on the SDN list
- Entity List
- Individuals and entities that are named on the Entity List are subject to specific export license requirements for anything that is subject to the EAR.
- If the University of Rochester wanted to send any tangible item (or information that is not the result of fundamental research or published/publicly available to a party on the Entity List) then the University would have to apply for and receive an export license from the U.S. Department of Commerce before sending/sharing that item or information
- Unverified List
- Parties listed on the Unverified List are ineligible to receive items subject to the EAR by means of an export license exception. Also, exporters must file an Automated Export System record for all exports to parties listed on the UVL and obtain a statement from such parties on the Unverified List prior to exporting, reexporting, or transferring to such parties any item subject to the EAR which is not subject to a license requirement.
- Department of State Arms Export Control Act Debarred Parties
- These individuals and entities have been convicted of violating or conspiracy to violate the Arms Export Control Act, and consequently are subject to "statutory debarment" pursuant to the AECA and the ITAR. They are prohibited from participating directly or indirectly in the export of defense articles (including technical data) and defense services.
ORPA, Global Engagement and Advancement have licenses to Visual Compliance to perform restricted party screening. Visual Compliance screens against the above named lists, along with many others, including federal debarment lists; FBI, Homeland Security, U.S. Marshal, Drug Enforcement Administration lists; and various restricted party lists maintained by other countries. If you have any questions about screening relevant parties, please reach out to ORPA and/or Global Engagement.
Also, the Consolidated Screening List is a free, publicly available, resource to perform restricted party screening against the lists noted above in the bullet points, along with a few others.
Restricted party screening should be a baseline due diligence step before entering into a contract, collaborations or sharing information or materials with a party.