Restricted party screening (RPS) is the process of screening potential denied parties involved in any export transaction for the purpose of complying with U.S. Export Control Laws.
- Conducting research and working with foreign collaborators?
- Shipping an item or transferring technology overseas or to a foreign end-user?
- Considering a new contract, grant, or funding agreement with foreign partners?
- Hosting foreign visitors to your site/lab?
These are just a few of the cases when RPS is necessary prior to engaging in a transaction with a foreign entity.
*RPS must be performed on each individual, entity, or company in the transaction.
**The VUMC Export Compliance (VUMC EC) Office will assist you in this process. Please email all requests to email@example.com with the details below.
What does VUMC EC need in order to complete RPS?
- A complete name of the person or entity to be screened - no acronyms/abbreviations
- A complete physical address for the entity (if known) - no PO Boxes
- The foreign country of destination
How do you know if a person or entity is restricted or denied?
VUMC EC screens all parties against Denied Persons Lists (DPL) and restrictions agencies from over 70 sources internationally. From time to time, entities will be added or removed to these lists on an on-going basis. As such, each of these sources are updated daily and provide maximum capability for compliance when screening is performed.
The results from the screens are kept for five (5) years past the date of last activity on the transaction. If you would like a copy of the RPS results, please let VUMC EC know, and we will forward to the record(s) to you.
What happens if a denied party is discovered?
In the event a company, entity or person on one of the DPLs appears to match a potential party in an export transaction, additional due diligence is required before proceeding.
Depending on which list the match was found, a match indicates either:
- there is a strict export prohibition
- a specific license requirement, or
- the presence of a "red flag"
Prior to taking any further actions, VUMC EC will consult the requirements of the specific list on which the company, entity or person is identified by reviewing the webpage of the agency responsible for the list for additional guidance.
How do I avoid dealing with restricted/denied parties?
The Bureau of Industry and Security (BIS) provides very helpful guidance when considering who to do business/collaborate with:
- Know your customer/collaborator.
- Look for Red Flags that can help you recognize potentially illegal transactions.
- Check the parties to your transaction against the DPLs - each organization should run RPS.
- Report illegal transactions or encouragement to violate international laws by any party to the transaction immediately.
Contact VUMC EC for assistance with RPS/DPL requests at firstname.lastname@example.org or at (615) 875--7577 at any time.