Restricted Party Screening Guidance and Procedures

What is restricted party screening?

Numerous U.S. government agencies (primarily the Departments of State, Commerce, and Treasury) maintain lists of individuals, companies, or entities barred or restricted from entering into certain types of transactions with U.S. individuals, corporations, and organizations, including Indiana University.

The lists include both U.S. and foreign individuals, entities, and organizations. The U.S. government updates these lists on a regular basis, meaning that individuals or entities with whom you are conducting business could be added to or removed from the list.

Engaging in business or other transactions with individuals, companies, or entities on these lists may result in civil penalties for Indiana University and civil or criminal penalties for the individual involved in the activities.

Prescreening is important. It can identify ineligible recipients and identify licensing requirements, so that you know about potential concerns or problems before you expend time or resources.

Conducting restricted party screening

Indiana University and its campuses use a web-based software program provided by eCustoms known as Visual Compliance to promptly conduct screenings against the various federally maintained lists. Visual Compliance also ensures automated periodic rescreening and documentation for audit purposes.

Restricted party screening at IU

The Office of Research Compliance currently conducts restricted party screening for Indiana University and will conduct restricted party screening on your behalf.

Most screening is done within three business days. The Office of Research Compliance recommends restricted party screening be conducted prior to:

  • signing any outgoing international Material Transfer Agreement
  • contracting with a foreign vendor, foreign party, or service provider
  • exporting equipment, technical data, software (including source or object code), samples, or supplies

To request Restricted Party Screening, please contact the Export Control Specialist.

To expedite the screening, please include a list of all known parties (companies, institutions, entities, or individuals) and the proposed agreement or activity along with their country of citizenship or business location.

Unit/departmental screening

For units/departments anticipating a large volume of screening requests, the Office of Research Compliance may authorize direct access to the Visual Compliance software.

To arrange for access and training on the use of the software, please contact the Export Control Specialist and describe the need for restricted party screening at the unit/departmental level.

U.S. government resources

For additional information on U.S. government screening lists and the obligations for prescreening, please visit the following:

Contact IU Export Control Specialist

Contact John Jay Miller, Export Control Specialist, at export@iu.edu or 317-274-7601. You may also schedule an in-person meeting at a campus location convenient for you.