Restricted Party Screening

Restricted Party Screening (RPS) is a service provided by the U-M Export Controls program that verifies whether an organization (e.g., company or university), individual, or country has had its export privileges restricted or revoked per the U.S. Departments of State, Commerce, or Treasury and is listed on any of the federal restricted party lists.  RPS is required by the federal government and is a critical component of U-M's efforts to prevent violations of U.S. Export Control laws.  U-M uses a software program that checks all of the federal lists simultaneously. 

Any interaction with foreign persons or entities should undergo Restricted Party Screening (RPS).  For example:

• Sponsored Research - When accepting funding from an international entity or when working on an export-controlled research project (screening conducted by ORSP or U-M Export Controls, initiated with the PAF)
• Visitors to U-M - Visiting scholars and corporate relations visitors prior to coming to U-M (screening conducted by your department or by U-M Export Controls, upon request)
• International Travel - When meeting potential foreign collaborators or speaking at a foreign university or institute (screening requested by you, conducted by U-M Export Controls)
• International Shipping - Sending equipment overseas for fieldwork or sending samples or data to international recipients (screening requested by you, conducted by U-M Export Controls, or by U-M Innovation Partnerships when initiated by an outgoing Materials Transfer Agreement)

The software U-M uses for the Restricted Party Screening process simultaneously searches the following restricted party lists, which are also combined in the U.S. government Consolidated Screening List.  The links below go to the federal web pages that further explain the purpose for each list and contain links to download the list.

Department of State (ITAR):

• Nonproliferation Sanctions - Parties that have been sanctioned under various statutes regarding weapons proliferation. Note:  the Federal Register is the only official and complete listing for nonproliferation sanctions determinations
• AECA Debarred List - Entities and individuals prohibited from participating directly or indirectly in the export of defense articles, including technical data, and defense services

Department of Commerce (EAR):

• Denied Persons List - Individuals and entities that have been denied export privileges. Any dealings with a party on this list that violate the terms of denial are prohibited.
• Unverified List - Individuals and entities who the U.S. Bureau of Industry and Security (BIS) has been unable to verify in prior transactions. The presence of a party on this list does not necessarily mean that the transaction cannot go forward, but it is a "red flag" that must be resolved prior to proceeding with the export. 
• Entity List - Parties whose presence in a transaction can trigger a license requirement supplemental to those elsewhere in the Export Administration Regulations (EAR). The individual listing specifies the requirements and policy for each party.

Department of Treasury (OFAC):

• Sanctioned Program and Country Information - Details the export controls restrictions (e.g., embargoes, targeted sanctions) to specific individuals, organizations, and countries
• Specially Designated Nationals List - Details individuals and companies owned or controlled by, or acting for or on behalf of, sanctioned countries. It also lists individuals, groups, and entities, such as terrorists and narcotics traffickers designated under OFAC sanction programs that are not country-specific.  Export Adminstration Regulations (EAR) require a license for exports or re-exports to any party on this list whose entry contains the following suffixes:  SDGT, SDT, FTO, IRAQ2, or NPWND.

U.S. export control regulations also identify certain countries that are subject to a comprehensive embargo or targeted sanctions.  

Definitions: 

• Comprehensive embargoes prohibit all exports/imports and other transactions without a license or other U.S. government authorization.  
• Targeted sanctions are prohibitions on trade in specified goods, technologies, and services with specific organizations (including foriegn governments) and persons.

Resources:

The list of countries per regulation (i.e.,  ITAR, EAR, and OFAC) and the sanctions change.  Use the following links to the federal resources to obtain the most current information.

• ITAR: Country Policies
• EAR:  Country Chart (PDF)
• OFAC:  Sanctions Program and Country Information