Restricted Party Screening FAQ’s

Frequently Asked Questions

UMBC is responsible for ensuring that we do not unlawfully engage with persons or organizations who may jeopardize compliance with U.S. export controls and trade sanctions regulations, and for documenting our due diligence when complying with those regulations. A U.S. Government export license may be required before proceeding with a collaboration, appointment, or financial transaction when persons or organizations are:
● On a list of companies or individuals restricted from receiving U.S. items, technology, software
or services (“Entity List”).
● Restricted from receiving some or all items subject to the U.S. Export Regulations unless the
exporter secures a license (“End Use/End User”).
● Owned or controlled by, or acting for or on behalf of, sanctioned or embargoed countries.
● Subject to trade and financial sanctions (“Specially Designated Nationals and Blocked Persons”).
● Convicted of violating or conspiracy to violate the Arms Export Control Act (“Debarred Parties”).
Additionally, Restricted Party Screening is used to identify persons and organizations that may present an
elevated risk of undue foreign influence.

● International collaborators: Individuals and Organizations
● International visitors including: Visiting Scholars, Visiting Postdocs, Visiting Faculty, Visiting
Students (e.g. VSR/VSRIs)
● Industrial affiliates
● Recipients of international shipments: Individuals and Organizations
● International funders – Individuals and Organizations

It is important to conduct a restricted party screening prior to shipping an item internationally and prior to doing business with, or providing services to, a foreign entity or individual.

The office of ORPC will conduct Restricted Party Screenings when notified of involvement of above Individuals or Organizations.

 

  • Australian Strategic Policy Institute (ASPI)
  • Visual Compliance
  • UMBC, USM Policies
  • Federal Regulations
  • Federal Agencies like Commerce, State Department, Treasury, FBI, etc.
  • EC List Service Association of University Export Control Officers (AUECO)
  • UMBC General Counsel, AVPR, & VPR
  • Outside Law Firms
  • CSET – Chinese Talent Program Tracker-https://chinatalenttracker.cset.tech/

 

  • Personnel from comprehensively sanctioned countries (Cuba, Iran, Syria, China, Russia or North Korea)
  • Politically exposed persons (PEPs), such as individuals who have close ties to a foreign government such as a foreign government minister, or relative of government officials.
  • Any unusual affiliations, including unofficial affiliations such as informally acting as an agent on behalf of others.
  • Foreign military affiliations
  • Any other unusual aspects of a transaction or inappropriate business arrangements that seems out of place.
  • If RPS screening produces any positive results for the person, or an organization, ORPC will review the results and provide you with guidance regarding any applicable regulations, export licensing or additionally required documentation you might need.
  • If there is no name match but there is a country alert, this doesn’t necessarily mean you have a restricted entity, but it does mean there are restrictions or sanctions applied to
    this country. ORPC will provide you with guidance on how to proceed.

 

  • RPS screening can take as little as three days to two weeks depending on the complexity of the screening. Because of this we recommend that you contact ORPC when learning that a RPS will need to take place.

To begin the RPS process please fill out this form so that we may begin the screening process.

The role and responsibility of the faculty is simple. To provide ORPC with as much information as possible so that our office may conduct a thorough search. No two RPS searches are the same and we will do our best to guide you through this process and to give you advice along the way. We will never ask you to contact any government agency directly that we might be using to aid us in our screening process. Any use of US government agencies is merely another tool to allow our office to do its due diligence in conducting the screening process.