Campus Responsibility for Conducting Restricted Party Screening
SBU Export Control Policy requires the Campus Community to conduct Restricted Party Screenings. All non-U.S. persons and all entities (foreign and domestic) must be screened for inclusion on any of the U.S. government's restricted party list prior to engaging in activities.
Related: Campus Compliance & Export Control Laws and Regulations
This document identifies the types of engagements (categories) and the person/office responsible for conducting the Restricted Party Screening.
See Appendix 2 for Category definitions.
Category |
Sub-Category |
Responsible Party |
---|---|---|
Collaborator |
Foreign Persons* |
Individual engaging Collaborator |
Consultant |
Foreign Persons |
Individual engaging Consultant |
Employee |
All |
Human Resources |
Independent Contractor |
Foreign Persons |
Individual engaging Independent Contractor |
Material Transfer Agreement |
Foreign Persons |
Office of the Vice-President for Research (OVPR) |
Memorandum of Understanding |
Foreign Persons |
Office of Global Affairs and OVPR |
Non-Disclosure Agreement |
Foreign Persons |
OVPR |
Other License Agreement |
Foreign Persons |
Procurement and OVPR |
Sponsor |
All** |
OVPR |
Subcontractor/Sub-recipient |
All** |
OVPR |
Technical Service Provider |
Foreign Persons |
Procurement |
Visitor |
Foreign Persons |
Individual hosting Visitor |
Wire Payment |
Foreign Persons |
Accounts Payable |
Exclusions
*Does not include: Current University employees.
*Does not include: Federal, state or local government authorities or agencies in the United States and their employees or other U.S. Institutions of Higher Education and their employees.
Research Foundation for SUNY Central Office Role
Provides the campus with licenses for the use of VC and conducts an annual batch screening** of the vendor file
Return to the Guidance & Procedures for Export Control Compliance