Restricted party screening (RPS) is the process of screening potential denied or restricted parties for the purpose of complying with U.S. Export Control Laws and Regulations. RPS is conducted as an integral, required measure for all exporting activities - including, but not limited to, every case type as found here.
- Restricted Party Screening (RPS) Survey
- Submit this RPS Survey to have any persons, institutions, businesses, companies, partners, organizations, or entities screened.
- ** Please note: This is not a background-check. **
- It is not necessary to submit the RPS survey above when any other form (from the list here) is submitted, as RPS is already a part of that case review.
- This RPS survey is for additional, separate, one-off, or ad hoc RPS requests and can be submitted at any time for a quick evaluation against the restricted or denied lists only (without any other context).
These are just a few of the cases when RPS is necessary prior to engaging in a collaboration, study, trial, or transaction with a foreign entity.
- Conducting research and working with foreign collaborators?
- Shipping an item or transferring technology overseas or to a foreign end-user?
- Considering a new contract, grant, or funding agreement with foreign partners?
- Hosting foreign visitors to your site/lab?
What does the Export Compliance office need in order to review your RPS request?
- A complete name of the person or entity to be screened - no acronyms/abbreviations
- A complete physical address for the entity (if known) - no PO Boxes
- The foreign country of destination, origin, or nationality
- Please follow these general guidelines and best practices when submitting an RPS request:
How do you know if a person or entity is restricted or denied?
The Export Compliance office screens all parties against Restricted, Blocked, Wanted, Sanctioned, Terrorist, or otherwise Denied Persons Lists (DPL) from over 100 domestic and international sources. Entities are added to and/or removed from these lists on a perpetual basis. As such, our RPS vendor updates and consolidates each of these sources daily to provide the most accurate tool for compliance when screening is performed.
The results from the screens are kept for ten (10) years past the date of last activity on the transaction. If you would like a copy of the RPS results, please let the Export Compliance office know, and we will forward to the record(s) to you.
What happens if a denied party is discovered?
In the event a company, entity or person on one of the DPLs appears to match a potential party in an export transaction, additional due diligence is required before proceeding.
Depending on which list the match was found, a match indicates either:
- there is a strict export prohibition
- a specific license requirement, or
- the presence of a "red flag"
Prior to taking any further actions, the Export Compliance office will consult the requirements of the specific list on which the company, entity or person is identified by reviewing the webpage of the agency responsible for the list for additional guidance.
How do I avoid dealing with restricted/denied parties?
The Bureau of Industry and Security (BIS) provides very helpful guidance when considering who to do business/collaborate with:
- Know your customer/collaborator.
- Look for Red Flags that can help you recognize potentially illegal transactions.
- Request a Restricted Party Screening from the export compliance office.
- Report illegal transactions or any encouragement by internal or external parties to violate international laws immediately.
Contact the Export Compliance office for assistance with RPS/DPL requests at export@vumc.org or at (615) 875-7577 at any time.