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Restricted Party Screening

Various U.S. government agencies (primarily the Departments of Commerce, State, and Treasury) maintain lists of individuals, companies, or entities barred or restricted from entering into certain types of transactions with U.S. individuals, corporations, and organizations, including ¹û¶³´«Ã½.

Engaging in research, business, or other transactions with individuals, companies, or entities on these lists may result in civil penalties for ¹û¶³´«Ã½ and civil or criminal penalties for individuals involved in the activities.

Early screening is important – it can identify ineligible recipients or licensing requirements, so that you know about potential concerns or problems before you expend time or resources.

Conducting Restricted Party Screening
The University of Toledo and a consortium of Ohio colleges and universities subscribe to a web-based service provided by  known as  .  The Visual Compliance service screens both persons and companies/organizations against a wide range of lists maintained by federal agencies, U.S. and international law enforcement, and foreign governments.  Visual Compliance also provides automated daily re-screening and documentation for audit purposes.

Under certain circumstances, person(s) may be asked to provide a passport or CV as documentation to prove he/she is not a restricted or debarred party.

Restricted Party Screening for Research Activities
The Office of Research and Sponsored Programs conducts restricted party screening for the ¹û¶³´«Ã½ research community.  Most screening is done within three business days.  The Office of Research and Sponsored Programs requires restricted party screening be conducted prior to:

• Executing an outgoing international Material Transfer Agreement
• Contracting with a foreign vendor, foreign party, or foreign service provider
• Exporting equipment, technical data, software (both source and object code), samples or supplies
• Collaborations with foreign researchers and institutions
• Adding new personnel to sponsored programs
• Contracting with federal and state institutions for sponsored research

Requests for Restricted Party Screening

Requests to screen persons should include: Full Name, Including Middle Name or Initial Date of Birth Country of Birth Current Citizenship

Requests to screen organizations/companies should include: Full Legal Name of Institution or Company Address, Including Country Website Address

Submit requests for research related Restricted Party Screening to Gary Rafe at RestrictedPartyScreening@¹û¶³´«Ã½.edu.

Unit/Departmental Screening & Training
Units/departments that process a large volume of screening requests may be authorized by the Office of Research and Sponsored Programs to access the Visual Compliance service directly.

To arrange for access and training on the use of the Visual Compliance service for restricted party screening, please contact Gary Rafe, ¹û¶³´«Ã½ Visual Compliance administrator, and describe the need for restricted party screening at the unit/departmental level.

Once access is granted to Visual Compliance, unit/department staff will need to attend training on how to use the database, recording data and dynamic screening alert resolution.

U.S. Government Resources
Additional information on U.S. government screening lists and the obligations for prescreening is available at the following sites:

Visual Compliance Restricted Party Screening Authorities
Authorities referenced by Visual Compliance Restricted Screening as of January 2022 can be found here.