The US government and its constituent agencies maintain a multitude of exclusion lists of individuals, companies, and other organizations that are somehow restricted from doing business with US entities. The three agencies with the majority of export control responsibilities, the Department of State, the Department of Commerce, and the Treasury Department all maintain lists of entities that have had their US export privileges revoked, or are banned or restricted from restricted from receiving exports from the United States. Entities listed can be domestically based or foreign. As an exporter, PSU is expected to ensure that any export transaction does not include an entity listed on one of the lists of restricted parties. If PSU completes a non-compliant transaction with a restricted party, a violation will have occurred. In addition to the export control lists, there are a myriad of other lists of restricted parties that would be of interest to those engaging in transactions with non-PSU parties.
To ensure that the University has the ability to screen entities for inclusion on lists of restricted parties, PSU subscribes to Visual Compliance™, a web-based tool that allows exporters to easily perform restricted party screenings. One screening simultaneously searches all US and many foreign exclusion lists and returns the results accompanied by information about the particular entry. Visual Compliance includes many other tools to assist export compliance professionals in their evaluations.
PSU has a limited number of Visual Compliance licenses available for use. University community members who have a need to perform a restricted party screening can contact the ECO to have a screening done. PSU community members who find themselves with an ongoing need to perform restricted party screenings should inquire about having a Visual Compliance account assigned to them.
There are many instances when it is advisable to perform a restricted party screening, including, but not limited to:
When shipping anything (excluding documents) to another country
When executing a contract or agreement
Before signing an outgoing international Material Transfer Agreement (MTA)
When exchanging technical data or technology with a foreign party
When hiring a foreign national (RPS is performed as a part of the I-129 deemed export process for H visas)
When inviting foreign visitors to campus
When sponsoring a foreign scholar (J visa)
As a part of any agreement that requires screening
Anyone subject to the requirements of a technology control plan
When a foreign party wishes to sponsor research or other work at PSU
All personnel and visitors associated with export controlled research
Most matches, particularly of individuals, turn out to be false hits. All matches must be investigated to confirm if the match returned by Visual Compliance is valid. Generally, there is enough biographical information about the match in Visual Compliance to make a determination of validity. If there is any question about whether a match is valid after an initial attempt to confirm the validity of the match, the ECO should be consulted for further assistance.
Contact:
Research and Graduate Studies
1600 SW Fourth Ave.
Portland, Oregon 97201
Phone: 503-725-9944
Fax: 503-725-8170
Email: export@pdx.edu