Restricted Party Screening
Screen before you collaborate, pay, ship, or host.
Federal law prohibits UM from doing business with, or providing services to, restricted individuals and entities, whether or not money changes hands. The Export Control Office screens outside parties for you, before the engagement begins.
Are you planning to collaborate with an entity or individual outside the university? To ensure compliance with federal laws and regulations, parties you collaborate or transact business with must be screened against federal restricted party lists before any collaboration or transaction begins. The Export Control Office conducts all screenings.
Why Are Screenings Important?
Federal law prohibits US citizens, permanent residents and protected individuals from doing business with or providing services (whether funds are exchanged or not) to restricted foreign or domestic individuals or entities.
These restrictions arise under several federal regulations, including the Export Administration Regulations (EAR), 15 CFR Parts 730-774; the International Traffic in Arms Regulations (ITAR), 22 CFR Parts 120-130; and the sanctions regulations of the Treasury Department’s Office of Foreign Assets Control (OFAC), 31 CFR Chapter V. Federal restricted party lists include the Commerce Entity List, the State Department AECA Debarred List, and the Treasury Specially Designated Nationals List.
How Do I Request a Screening?
One party per form. Each individual or entity to be screened must be submitted on its own form. Do not list more than one party on a form.
Download the Restricted Party Screening Request Form (PDF), complete one form for each party, and email it to the Export Control Office at exportcontrol@mso.umt.edu.
The Export Control Office enters every screening into Visual Compliance, its restricted party screening system. Each name only needs to be entered once. It is regularly rechecked as the federal restricted party lists change, and the office receives a notification if the name is later added to a restricted list.
Screenings Should Be Done Before the Following Interactions With Third Parties
- discussing plans to engage in sponsored projects or draft a proposal for sponsored research
- considering sponsored research collaborations or appointments
- exchanging personnel, materials, data, confidential information or money with foreign persons, academic institutions, governments, companies or other foreign entities
- entering contracts with foreign or domestic parties
- shipping anything to an international individual or entity
- hosting visitors to the university
Some Units Within the University Have These Checks Built Into Their Processes
- Contracts and Purchasing Services
- Central Accounting Services
- Office of Sponsored Programs
- International Programs J-1 Visa requests
- Export Controls: checks individuals paid on federal grants and J-1 visa researchers
- Office of Technology Transfer
Questions? Contact the Export Control Office at exportcontrol@mso.umt.edu.