Restricted Entity Screening Responsibilities
Overview
The University conducts Restricted Entity Screening as part of its export control and research security compliance programs. Responsibility for conducting screening depends on the type of activity and the University office coordinating the engagement.
The table below identifies the primary office or individual responsible for conducting Restricted Entity Screening for common research and administrative activities.
| Activity | Entity to be Screened | Primary Responsible Party |
|---|---|---|
| Collaborator | Foreign Persons* | Individual engaging the collaborator |
| Consultant | Foreign Persons | Individual engaging the consultant |
| Employee | All | Human Resources |
| Independent Contractor | Foreign Persons | Individual engaging the independent contractor |
| Material Transfer Agreement (MTA) | Foreign Persons | Intellectual Property Partners |
| Memorandum of Understanding (MOU) | Foreign Persons | Office of Global Affairs and OVPR |
| Non-Disclosure Agreement (NDA) | Foreign Persons | Intellectual Property Partners |
| Other License Agreements | Foreign Persons | Procurement |
| Sponsor | All** | Office for Research and Innovation |
| Subrecipient / Subcontractor | All** | Office for Research and Innovation |
| Technical Service Provider | Foreign Persons | Procurement |
| Visitor | Foreign Persons | Individual hosting the visitor |
| International Wire Payments | Foreign Persons | Accounts Payable |
Screening Exceptions and Notes
* Screening Exceptions
For activities identified as requiring screening of Foreign Persons, screening is not required for:
- Current University employees.
- U.S. federal, state, or local government agencies and their employees.
- U.S. institutions of higher education and their employees.
** Research Foundation Screening
The Research Foundation for SUNY Central Office conducts an annual batch screening of the vendor file and provides the University with access to Restricted Entity Screening software.
Additional ORS Review
The table above identifies the primary responsibility for conducting Restricted Entity Screening. Screening alone does not determine whether an activity may proceed.
Depending on the nature of the proposed activity, additional review by the Office of Research Security (ORS) may be required to evaluate export control, sanctions, research security, licensing, or other applicable requirements.
Potential or unresolved matches should be referred to ORS for review before the activity proceeds.
For instructions on conducting a screening and handling potential matches, review How to Conduct a Restricted Entity Screening.
Need Assistance?
If you are uncertain whether Restricted Entity Screening is required, who is responsible for conducting the screening, or whether additional ORS review is needed, contact the Office of Research Security before proceeding with the activity.