To protect national interests, U.S. export control laws require U.S. entities such as the Lab to conduct Restricted Party Screenings (RPS). The screenings are to ensure that the entity does not engage in activities with sanctioned or denied entities or persons, whether in the U.S. or abroad. The U.S. government publishes various lists of these “Denied Parties,” with different prohibitions and requirements for each list. Both the Lab and you as an individual can incur civil and criminal penalties if you engage in activities with Denied Parties.
A positive match on a RPS List may mean a:
- strict export prohibition,
- specific export licensing or other requirements (e.g. obtain assurance statements, reporting, etc.), or
- a “red flag” designation requiring additional due diligence before proceeding with the activity.
To ensure that the Lab is in compliance, all principal investigators should conduct online Restricted Party Screening on the collaborators, partners, sponsors, and others they will be working with, and their organizations, and escalate any red flags or potential positive matches to their division’s export liaison or the Export Compliance Office. This screening should be completed prior to any work being performed. Some standard Lab processes, such as Memorandum of Understanding, Foreign Visits and Assignments, Shipping, Procurement, and Intellectual Property Office activities include the Restricted Party Screening as part of its process and you do not have to do it as a discrete step.
Visit the Lab’s Export Control website for additional information.