Restricted Entity Screening
Overview
Restricted Entity Screening is the process of reviewing individuals and organizations against U.S. government restricted party and sanctions lists before engaging in certain research, educational, service, or business activities.
Federal agencies maintain restricted party and sanctions lists identifying individuals, organizations, and other entities that may be subject to export restrictions, sanctions, licensing requirements, or other legal limitations. Screening helps the University identify activities that may require additional review before proceeding.
The Office of Research Security (ORS) administers the University's Restricted Entity Screening Program and provides guidance when screening identifies a potential match or additional review is required.
Important: A potential match on a restricted party or sanctions list does not necessarily mean that the proposed activity is prohibited. However, the activity should not proceed until the potential match has been resolved.
Common Considerations
Restricted Entity Screening compares the names of individuals and organizations against applicable U.S. government restricted party and sanctions lists.
Screening helps identify whether export control, sanctions, licensing, research security, or other requirements may apply to a proposed activity.
Restricted Entity Screening may be required for certain University activities involving individuals or organizations, including:
- International collaborations
- Foreign sponsors
- International visitors
- Foreign national employees
- International research agreements
- International shipments or transfers
- Equipment or other purchases
- Service providers
- Subrecipients
- Consultants
- International organizations
Screening requirements depend on the activity and applicable University procedures. Screening may also need to be repeated when circumstances change or at other points during an activity.
Review the Restricted Entity Screening Responsibilities guidance to determine when screening is required and who is responsible for conducting it.
Responsibility for conducting Restricted Entity Screening depends on the type of activity.
Depending on the activity, screening may be conducted by:
- Principal Investigators or other University personnel
- Departments or administrative units
- Procurement
- Sponsored Programs
- Human Resources
- Office of Research Security
- Other University offices
Review Restricted Entity Screening Responsibilities to identify the responsible office or individual for a particular activity.
If screening identifies a potential match, additional review may be required.
Many potential matches are false positives that can be resolved by comparing identifying information associated with the screening result.
If a potential match cannot be resolved:
- Do not proceed with the activity.
- Contact the Office of Research Security.
- Provide the screening results and available supporting information.
ORS will review unresolved or potential positive matches and determine whether the individual or organization is a listed party and whether any federal or institutional requirements apply.
Stony Brook University uses a University-approved screening platform to compare individuals and organizations against applicable U.S. government restricted party and sanctions lists.
The screening process generally includes:
- Screening the individual's or organization's full legal name.
- Reviewing potential matches.
- Refining the screening when necessary.
- Documenting how potential matches are resolved.
- Referring unresolved or potential positive matches to ORS.
For step-by-step instructions, review How to Conduct a Restricted Entity Screening.
Frequently Asked Questions
Does every international collaborator require screening?
Screening requirements depend on the activity and applicable University procedures. Review the Restricted Entity Screening Responsibilities guidance to determine whether screening is required.
Do U.S. individuals and organizations ever require screening?
Yes. Restricted Entity Screening is not limited to foreign individuals or organizations. U.S. individuals and organizations may also appear on federal restricted party or sanctions lists.
Does a potential match mean the activity is prohibited?
Not necessarily. A potential match requires review to determine whether the individual or organization is the listed party and whether any restrictions apply.
How often should screening be performed?
Screening should be conducted as required by applicable University procedures. Additional screening may be appropriate when circumstances change or at other points during an activity.
What should I do if I cannot resolve a potential match?
Do not proceed with the activity. Contact ORS and provide the screening results and available supporting information for review.
University Resources
| Resource | Description |
|---|---|
| Restricted Entity Screening Responsibilities | Identifies the University office or individual responsible for conducting screening based on the type of activity. |
| How to Conduct a Restricted Entity Screening | Step-by-step instructions for using the University's screening software. |
Need Assistance?
If you are uncertain whether Restricted Entity Screening is required, cannot resolve a potential match, or have questions about screening requirements, contact the Office of Research Security before proceeding with the activity.