Restricted Party Screening (RPS) is the process of screening individuals and entities against U.S. government restricted and prohibited party lists to identify potential restrictions on transactions or other interactions with non-US persons and/or entities. WashU conducts RPS as part of its export control, sanctions, and research security compliance programs and to support applicable federal funding-agency requirements. RPS is one component of WashU’s compliance review. For export control requirements, screening results may not, by itself, determine whether an activity is permitted.
How to conduct or request a RPS
What is screened centrally?
When screening is required for other activities
Potential match, denied (prohibited), and/or restricted
Frequently Asked Questions
How to conduct or request a RPS (for activities not screened centrally)
There are two options for conducting an initial Restricted Party Screening (RPS) review before engaging with an individual or entity.
- Option 1 – Request Screening from Export Control
Use this option when you need to screen or assess potential engagement with an individual or entity, when you are unsure whether the individual or entity has already been screened through a central office, or the activity involves higher-risk international activity.- Contact Export Controls with the individual’s name, affiliations or associated entity, foreign funding (sources when available), and relevant details about the proposed activity.
- The export control office will conduct the screening using the university’s institutional screening software, review any potential matches, determine whether it is a prohibited activity, and communicate whether there is a match and guidance on how to address, if applicable.
- Option 2 – Self Screening
To complete the self-screening process:- Search the individual or entity using the US Department of Commerce Consolidated Screening List (CSL) AND
- Search the WashU Restricted Party Supplemental List
- If there is no potential match, then there are no known export control restrictions or prohibitions.
- If a potential match is identified or if you are unsure of the results, contact Export Controls for further review.
Self-Screening does not constitute an official university determination that an individual or entity is cleared to participate in an activity or transaction.
What is screened centrally?
RPS is incorporated into several existing university processes based on the activity with screening conducted by the responsible university office and potential matches or other concerns referred to Export Controls for additional review.
| Process | Screening Examples | Responsible Office |
|---|---|---|
| Research Agreements | Foreign sponsors, collaborators, service providers, and other foreign entities | JROC |
| Sponsored research/subawards | Foreign subrecipients and prime recipients | OSRS/JROC |
| Material Transfer Agreements | Foreign entities and individuals providing or receiving materials | OTM/Export Controls/EHS |
| Inter-Institutional Agreements | Inbound and outbound inter-institutional agreements | OTM/Export Controls |
| Licensing/option agreements | Foreign entities and individuals receiving IP or materials (with or without a fee) | OTM/Export Controls |
| Vendors | New and active vendors | Accounting |
| Financial Transactions | Large payments to foreign entities and smaller transactions involving payment to a foreign entity or individual | Treasury/Accounting |
| Visa Processing | Foreign applicants and sponsoring institutions | OISS |
| Technology Control Plans | Personnel authorized to access controlled technology or technical data | Export Controls |
| MOUs | All international MOUs for Danforth and Medical Campus | Provosts Office |
| International shipments | Foreign recipients, destinations, and materials, processed through a central office such as OTM or EHS | Export Controls/EHS |
When screening is required for other activities (not screened centrally)
If the individual or entity is already being processed through an established university workflow noted above, screening is already occurring through that process. A RPS should be initiated if:
- A foreign collaborator or organization, or other foreign entity is being engaged outside an established university workflow or process.
- A new, formal, or informal collaboration, appointment, or other relationship with a foreign person or entity is being considered.
- Research materials will be sent outside the United States and not processed through an established process or workflow.
- International activities involve a foreign individual or entity and there is a question about potential export control concerns, research security restrictions, or other sanctions.
- Plans are being discussed to engage in a collaboration or sponsored project with a foreign person or entity.
- Personnel, materials, data, confidential information, or funds will be exchanged with foreign persons, academic institutions, governments, companies, or other foreign entities.
- Your involvement in a research collaboration or appointment involving a foreign person or entity is being considered.
- A foreign visitor, visiting researcher, or visiting speaker is being hosted at WashU and is not otherwise screened through OISS, such as individuals whose visa sponsorship, immigrations status, or other international appointments being processed by OISS.
- Any other circumstance raising question about whether US government restrictions or prohibitions apply.
- It is unclear whether an individual or entity has already been screened.
When in doubt, contact Export Controls to determine whether screening is required and if the screening will be completed through an established university process.
Potential match, denied (prohibited), and/or restricted
Not all restricted-party listings impose the same restrictions. A potential match does not necessarily mean the individual or entity is restricted or the activity is prohibited. Export Controls will review potential matches to confirm the identity and determine any applicable restrictions, licenses, or authorizations before the activity proceeds.
The categories below are general descriptions and do not capture every restriction that may apply. Restrictions can vary based on the specific list, party, country, transaction, item, technology, or information involved. Export Controls will determine whether an activity may proceed and whether a license, exception, or other authorization is required. In general:
- Denied/Debarred Parties: Not approved for transactions or activities. WashU and US persons may not engage in transactions or activities with a denied or debarred party unless specifically authorized by the applicable U.S. government agency.
- Restricted Parties: Transactions or activities are generally not permissible without special authorization, such as a license or other applicable exception/authorization. Additional review by is required before proceeding.
- Countries of Concern: Certain countries present heightened export-control, sanctions, and research-security concerns. Countries of Concern currently include the People’s Republic of China, North Korea, Russia, Iran, Cuba, and Venezuela. In addition, certain countries and regions are subject to comprehensive U.S. sanctions and/or stringent export controls. For some activities, the applicable U.S. government agency has a presumption or policy of denial for license applications, meaning that obtaining authorization may be unlikely even where a license could technically be requested.
Frequently Asked Questions
- Is a RPS the Same as an Export-Control Review?
No. RPS is a screening step used to identify whether an individual or entity appears on a Denied or Restricted-party list. A clear screening result does not mean the activity is automatically permitted, and a potential match does not necessarily mean the activity is prohibited. An export control review will consider the broader circumstances of the activity including the country, individuals, items or information, scope and purpose of the work, and appliable sanctions or prohibitions. - Is RPS the same as checking for funding-agency restrictions?
No. Funding agencies may impose additional restrictions on certain individuals entities, countries, collaborators, other activities. Some of these restrictions may be identified by RPS, but will require review of the specific award terms, federal requirements, or research security restrictions. A clear RPS does not mean that all funding agency requirements have been satisfied. - Do I need to screen every foreign collaborator?
Not Necessarily. Many individuals and entities are screened through established university processes. Duplicate screening is not necessary when RPS is already incorporated into the workflow. However, If you are unsure whether screening has occurred, contact Export Controls. - If there is no RPS concern, could an activity still have an export-control or funding-agency restriction?
Yes. RPS addresses whether an individual or entity has been identified on applicable restricted or prohibited parties lists. Other restrictions may apply based on the country of destinations, technology or information involved, nature of the activity, funding source, award terms, or other federal requirements. - What should I do if I receive a potential match?
Do not proceed until the potential match has been reviewed. Contact Export Controls or the university office conducting the screening. A potential match does not necessarily mean the individual or entity is restricted; Export Controls can determine whether the match is a true match and whether additional review or information is required. - Does RPS apply only to export controls?
No. RPS is used as part of several university compliance processes, including export controls, sanctions, research security, and applicable federal funding-agency requirements. The screening process itself does not replace the broader compliance review that may be required for a particular activity. - How are RPS, export controls, and funding-agency restrictions different?
While these requirements may overlap, they address different compliance considerations:- RPS: Screens the person or entity against restricted and prohibited party lists.
- Export controls/sanctions: Evaluate the activity, including the parties, country, items, technology, information, and destination.
- Funding-agency restrictions: Evaluate requirements or restrictions imposed by the funding source or award, which may apply separately from RPS or export controls.