Federal agencies maintain a number of restricted-party and national-security lists identifying foreign individuals, universities, companies, and other organizations that present sanctions, export-control, research-security, or other national-security concerns. USC incorporates these lists into its institutional screening and review processes and also identifies certain additional institutions as presenting heightened research-security risk.
The restrictions associated with these lists vary. Depending on the applicable list and activity involved, a relationship with a listed party may be prohibited, require prior authorization from a government agency or research sponsor, affect eligibility for federal research funding, or require heightened diligence, mitigation, or other safeguards.
Restricted Party Screening
Please reach out to OEC for screening assistance or to request review of a current or proposed relationship to determine whether any restrictions apply.
OEC maintains a screening tool allowing for prompt identification of individuals, universities, companies, and other organizations that present sanctions, export-control, research-security, or other national-security concerns. The screening tool performs a comprehensive, nightly screen against all relevant sanctions lists and provides alerts in the event an individual or entity appears on one or more lists.
Please see the links below to review the lists that frequently implicate university relationships with foreign entities and individuals:
- Department of War Section 1286 List. Identifies foreign institutions and entities determined by DoW to present specified research-security and foreign-influence concerns.
- Department of War Section 1260H List. Identifies entities determined by DoW to qualify as Chinese military companies operating directly or indirectly in the United States.
- Department of Commerce Entity List. Identifies foreign persons and organizations subject to specified export licensing requirements.
- Department of the Treasury sanctions lists, including the OFAC Specially Designated Nationals and Blocked Persons List, which impose restrictions on dealings with designated persons and entities.
- USC Other High-Risk Institutions. Identifies institutions presenting heightened research-security concerns, including institutions identified in connection with congressional scrutiny regarding activities believed to bolster China’s military and intelligence-gathering capabilities.
- Department of Commerce Military End-User List. Identifies foreign entities subject to heightened export-control restrictions and licensing requirements because of their designation as military end users under the Export Administration Regulations.
- Department of Commerce Denied Persons List. Identifies individuals, companies, and organizations that have been denied export privileges and are prohibited from participating in specified transactions subject to the Export Administration Regulations.
- Department of State Debarred Parties List. Identifies persons (including entities and individuals) convicted of violating or conspiracy to violate the Arms Export Control Act (AECA)
- Section 889 List. Identifies prohibited telecommunications companies of the People’s Republic of China (including aliases, affiliates, and subsidiaries).
- Section 5949 List. Identifies prohibited semiconductor companies of the People’s Republic of China (including aliases, affiliates, and subsidiaries).
- Federal Communications Commission Covered List. Identifies communications equipment and services (Covered List) entities that are deemed to pose an unacceptable risk to the national security of the United States or the security and safety of United States persons.
- Department of Homeland Security Uyghur Forced Labor. Identifies entities associated with forced labor involving the Xinjiang Uyghur Autonomous Region or other government labor schemes in the People’s Republic of China whose goods are subject to a rebuttable presumption against importation into the United States.
- Annex to Executive Order (EO) 14032. Identifies Chinese companies initially made subject to restrictions on U.S. persons’ transactions in publicly traded securities because of their involvement in China’s defense and related materiel or surveillance-technology sectors.
Relationships and Activities Subject to Screening
Restricted-party screening is required whenever USC or its employees seek to enter into a relationship or activity involving an external individual or entity, foreign or domestic.
- Research relationships: Industry sponsors, subcontractors, collaborators, and other research partners.
- Institutional relationships: Parties to MOU’s, affiliation agreements, scientific exchange programs, research collaborations, and academic exchange agreements.
- Contracting and other transactions: Vendors and suppliers, parties to Non-Disclosure Agreements (NDA’s) and Material Transfer Agreements (MTA’s)
- International activities: Recipients of international shipments, J-1scholars, and visiting international delegations
- Gifts and philanthropy: Donors and other individuals or entities associated with gifts, philanthropic contributions, or related advancement activities
If you have questions or need screening assistance determining who should be screened and/or when to perform screening, please contact Michael Litchman in the Office of Ethics and Compliance at mlitchma@usc.edu, or e-mail compliance@usc.edu.