Restricted party screening is an important part of UCSB’s export control compliance program and is used to identify restricted parties prior to engaging in activities which could result in export control violations. Export control regulations prohibit U.S. citizens from engaging with certain foreign individuals or organizations, which may include foreign government officials or academic institutions. At UCSB, software tools are used to conduct this screening and identify situations where permission from the government may be required. The screening tool compares the search terms with information published by the U.S. government.
Restricted party screening should take place prior to engaging in a transaction or export and should be performed for international activities. Screens should include every non-UC individual or entity involved in the transaction, including the end-user, affiliated entity for international scholars and any other parties involved with the transaction, including partner resources such as supercomputing centers. In addition to the following list, researchers are encouraged to contact the Export Control Officer prior to considering foreign research collaborations or foreign appointments.
Restricted party screening should be conducted on the following transactions:
- Financial transactions with an international element (e.g., purchases from international vendors, reimbursements to international parties)
- Awards or agreements with international entities (e.g., contracts/grants, sales and service, subawards, gifts)
- Formal international collaborations (e.g., visiting scholars & postdocs, Memorandums of Understanding with international institutions, or Non-disclosure Agreements with international entities)
- International shipments (e.g., physical transfers outside the U.S., transfers of controlled technology inside or outside the U.S.)
In addition to the above situations, extra care must be taken when engaging in activities with comprehensively sanctioned countries and regions. Please work with the Export Control Officer prior to working in, or with entities located within, any of the following areas:
- Crimea region
- Cuba
- Donetsk region
- Iran
- Luhansk region
- North Korea
- Sevastopol region
- Sudan
- Syria
Several different offices at UCSB perform restricted party screening as part of their normal business operations. University units who would like access to the screening tool should contact the Export Control Officer. If the screening tool returns a match, it is possible that the entity or person screened is a restricted party and the Export Control Officer must be contacted. Any export compliance concerns must be addressed before proceeding with the transaction.
Agreements and Identifying Export Compliance Risks
Individuals responsible for negotiating and signing agreements on behalf of the University should be aware of scenarios that could trigger export compliance requirements. The Export Control office offers training to these individuals and plays an important role in the review of these scenarios.
If the following scenarios are identified, please contact exportcontrol@research.ucsb.edu to discuss.
- Publication restrictions other than reasonable time periods for Patent or sponsor proprietary information reviews
- Foreign national participation restrictions or a requirement to provide researcher citizenship information
- Involvement of restricted parties - identified through Restricted Party Screening
- Involvement of, or work conducted in, embargoed countries/regions
- Physical exports of scientific equipment to international destinations - excluding mobile devices kept under the owner’s control
- Requirement to sign a separate End-user Agreement - should not be signed until reviewed by the Export Control Officer
- Sales or services to foreign entities or governments
- Receipt of controlled items (commodities, software, or technology), or knowledge that such transactions will take place
- Sponsor request to claim research results as their proprietary information
Contact
If you have any questions, please contact the Export Control Officer at exportcontrol@research.ucsb.edu