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.

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

Campus Responsibility for Conducting Restricted Party Screening

Category

Sub-Category

Responsible Party