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A restricted party is any individual, company, or organization prohibited by federal law to receive export-controlled items, information, or technology. The U.S. Departments of State, Commerce, and the Treasury each maintain lists of restricted parties.
The University of Michigan (U-M) should not enter into transactions (e.g., research agreements, research-related activities) with restricted parties. Therefore, U-M screens international entities, shipping destinations, travel destinations, and persons (e.g., international visitors, research sponsors, research collaborators) against federal restricted party lists.
When to Request Restricted Party Screening
Multiple U-M offices conduct restricted party screening (RPS) as a standard business practice. You do not have to request RPS in the following situations:
- The U-M Office of Research (UMOR) Export Controls program screens personnel on export-controlled sponsored research projects
- The Office of Research and Sponsored Projects (ORSP) screens all research sponsors
- The Office of the Provost screens collaborators on international memorandums of understanding (MOUs)
- The Office of Technology Transfer (OTT) screens outgoing materials transfer agreements (MTAs) to international destinations
- Procurement Services screens vendors entering into purchasing contracts with the university
You are expected to request restricted party screening prior to any anticipated research-related activities (e.g., interactions, such as collaborations, discussions, etc.) with foreign individuals or organizations or travel to international destinations.
Examples of common research-related activities in which you should request RPS before arrangements are made include:
- Receiving a request to give a talk at a foreign university or institute (see International Travel & Export Controls for related information)
- Extending an invitation to a foreign national to tour a high technology facility at U-M, or being invited to tour an international facility
- Shipping of equipment to a foreign country for fieldwork or other research
- Sending export-controlled samples or data to international receipients
How to Request Restricted Party Screening
E-mail the U-M Export Controls Officer with:
- A description of your situation or plans
- Dates or approximate dates of the activity, if known
- Names of organizations and individuals with whom the interactions are planned
- Foreign countries associated with the interactions
- Descriptions of the items/information to be shipped or taken (i.e., exported) to foreign destinations
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. Because restricted party screening may be complicated, U-M recommends that you email the U-M Export Control Officer to request screening, as opposed to reviewing the multiple lists yourself.
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 OTT 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.
- 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.
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.