Restricted Party Screening For Export Control Compliance

By Author: Sumit Malik
Total Articles: 49
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Restricted Party Screening seek to identify parties that may be prohibited from receiving some or all items subject to export control regulations, unless the exporter secures a license. Screenings of known contacts against these lists should also be conducted prior to international travel.

The U.S. Government periodically publishes laws, regulations, executive orders, or directives that identify entities (e.g., companies, organizations, institutions, and individuals) that are prohibited or restricted from engaging in specific transactions or activities (e.g., receiving an export of U.S. technology; providing services to or receiving services from U.S. entities; or receiving U.S. government funds). These restrictions can, and in some cases do, apply to the activities of institutions of higher education. However, ...
... it is important to note that not all restrictions are comprehensive prohibitions; some are limited prohibitions or simply require additional government review and approval (i.e., licensing) but require additional risk consideration by the University. Historically U.S. government agencies have published comprehensive lists of restricted entities; however, recent federal legislative actions present a distinct compliance challenge by using broadly descriptive language (e.g., ABC Company and its subsidiaries and affiliates) without publishing a comprehensive list of restricted entities.

To prevent inadvertent violations of applicable restrictions, the University of Virginia performs restricted party screening as part of standard business processes to identify and manage or prevent activities involving restricted entities. Restricted party screening supports compliance with export control and sanction program regulations as well as government (federal and state) non-procurement orders and other initiatives.