Restricted Party Screening
Various U.S. government agencies (primarily the Departments of Commerce, State, 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 Ä¢¹½ÊÓƵ.
Engaging in research, business, or other transactions with individuals, companies, or entities on these lists may result in civil penalties for Ä¢¹½ÊÓƵ and civil or criminal penalties for individuals involved in the activities.
Early screening is important – it can identify ineligible recipients or licensing requirements, so that you know about potential concerns or problems before you expend time or resources.
Conducting Restricted Party Screening
The University of Toledo and a consortium of Ohio colleges and universities subscribe
to a web-based service provided by  known as  . The Visual Compliance service screens both persons and companies/organizations
against a wide range of lists maintained by federal agencies, U.S. and international
law enforcement, and foreign governments. Visual Compliance also provides automated
daily re-screening and documentation for audit purposes.
Under certain circumstances, person(s) may be asked to provide a passport or CV as documentation to prove he/she is not a restricted or debarred party.
Restricted Party Screening for Research Activities
The Office of Research and Sponsored Programs conducts restricted party screening
for the Ä¢¹½ÊÓƵ research community. Most screening is done within three business
days. The Office of Research and Sponsored Programs requires restricted party screening
be conducted prior to:
- Executing an outgoing international Material Transfer Agreement
- Contracting with a foreign vendor, foreign party, or foreign service provider
- Exporting equipment, technical data, software (both source and object code), samples or supplies
- Collaborations with foreign researchers and institutions
- Adding new personnel to sponsored programs
- Contracting with federal and state institutions for sponsored research
Requests for Restricted Party Screening |
Requests to screen persons should include:
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Requests to screen organizations/companies should include:
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Submit requests for research related Restricted Party Screening to Gary Rafe at RestrictedPartyScreening@Ä¢¹½ÊÓƵ.edu. |
Unit/Departmental Screening & Training
Units/departments that process a large volume of screening requests may be authorized
by the Office of Research and Sponsored Programs to access the Visual Compliance service
directly.
To arrange for access and training on the use of the Visual Compliance service for restricted party screening, please contact Gary Rafe, Ä¢¹½ÊÓƵ Visual Compliance administrator, and describe the need for restricted party screening at the unit/departmental level.
Once access is granted to Visual Compliance, unit/department staff will need to attend training on how to use the database, recording data and dynamic screening alert resolution.
U.S. Government Resources
Additional information on U.S. government screening lists and the obligations for
prescreening is available at the following sites:
Visual Compliance Restricted Party Screening Authorities
Authorities referenced by Visual Compliance Restricted Screening as of January 2022
can be found here.