U.S. Government agencies maintain lists of individuals and entities barred or restricted from entering into certain types of transactions with U.S. persons. Those lists include not only specially designated nationals but also individuals, foreign universities, and businesses that have been debarred by the Department of State or restricted by the Department of Commerce because of previous violation of the regulations. Collaborating with an individual who is from a restricted entity – particularly if located in a “foreign country of concern” (FCOC) – is extremely high risk. FCOCs are currently defined as China, Russia, North Korea, and Iran per section 10612 of the CHIPS Act of 2022.
Please contact the USC Office of Ethics and Compliance before engaging in any activity involving the sanctioned countries, entities, or individuals. If you are unsure of the status of an entity or individual, please reach out to OCEC prior to any engagement.
Click the link to download the Restricted Parties one-sheet.
Check a University/Party Status
OCEC maintains a screening tool allowing for prompt identification of any sanctions or export controls that may apply to a given entity or individual. Please reach out to OCEC with any questions about whether a transaction with a particular entity or individual may be subject to restrictions.
What USC Screens:
Below is a list of categories of entities that USC screens or recommends should be screened prior to formal engagement or executed agreement with such a party:
- Industry research sponsors (domestic and international)
- Parties to inter-institutional MOU and MOA joint venture and affiliation agreements, including (but not limited to) scientific exchange programs, research collaboration, and academic exchange agreements
- Vendors (domestic and international)
- Non-Disclosure Agreement (NDA) and Material Transfer (MTA) partners
- Recipients/consignees of international shipments
- J-1 Visa Visitor Exchange candidates
- International donors of financial gifts
Screening is also advisable for:
- Visiting international delegations to the campus
- Foreign Gifts
- Subcontractors (domestic and international)
Please reach out to OCEC for guidance as to whether screening is necessary in any of these circumstances.
If you have questions or need assistance determining who should be screened and/or when to perform screening, please contact the Assistant Director of Export Controls. For additional information, please see the Department of Commerce Bureau of Industry and Security (BIS) resource Export Compliance Resources for Academic Institutions.
Restricted Party Screening – Quick FAQs
Click on each question below to expand and learn more.
OFAC SDN List: Contains blocked individuals, entities, vessels, and aircraft. No interaction is allowed.
Department of Defense (DoD) 1286 List: Lists foreign institutions involved in problematic activities per the National Defense Authorization Act (NDAA). Refer to the current DoD Matrix.
BIS Entity List: Includes foreign persons/entities requiring special licenses for exports. Often, license requests are denied.
Australian Unitracker: A research-based list (not an official denied list) that sometimes overlaps with U.S. government lists.
Contact Emily Pender (epender@usc.edu) for screenings related to collaborators, appointments, co-authors, or conference organizers.
Contact OCEC for guidance. Activities like presenting already-published work may be allowed in limited cases, but collaborations with restricted entities—especially in countries like China, Iran, North Korea, and Russia—are typically prohibited.
Most collaborations with someone from a restricted entity are not permitted. There are some limited exceptions, so contact the Office of Ethics and Compliance for more specific guidance.
Immediately contact OEC for guidance on how to navigate disclosure, export controls, and potential research integrity considerations.
It depends. Consider:
- Benefit to you/USC
- Any overlap with federal funding
- Whether you’ll be listed as co-author
Consult with OEC for a risk assessment.
Generally, no.
It reviews collaborations, affiliations, and funding sources using a risk matrix to evaluate particular researchers and projects, and may require additional due diligence or risk mitigation measures as a condition of performing the research project.
- Requires express government authorization in the form of a license prior to any exports. These authorizations are usually denied.
- Visitors with valid visas may work on fundamental research, but cannot share data with their home (denied) institutions.
- Collaborating with such individuals may disqualify you from federal funding and is viewed as high-risk by agencies.
DoD 1286 List
As mentioned above, the 1286 List includes foreign institutions that have been confirmed as engaging in problematic activity as described in Section 1286(c)(8)(A) of the NDAA for FY 2019. The list made publicly available by the DoD is published on our website here: Department of Defense (DoD) 1286 List.
DoD 1260H List
The DoD 1260H list (also known as the 1260H CMC List) is an annually updated roster of “Chinese military companies” operating, directly or indirectly, in the United States. The list made publicly available by the DoD is published on our website here: Department of Defense (DoD) 1260 List.