Campus Responsibility for Conducting Restricted Party Screening

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SBU Export Control Policy requires the Campus Community to conduct Restricted Party Screenings. All non-U.S. persons and all entities (foreign and domestic) must be screened for inclusion on any of the U.S. government's restricted party list prior to engaging in activities.

Related: Campus Compliance & Export Control Laws and Regulations

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This document identifies the types of engagements (categories) and the person/office responsible for conducting the Restricted Party Screening. 

See Appendix 2 for Category definitions.

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Category	Sub-Category	Responsible Party
Category Collaborator	Sub-Category Foreign Persons*	Responsible Party Individual engaging Collaborator
Category Consultant	Sub-Category Foreign Persons	Responsible Party Individual engaging Consultant
Category Employee	Sub-Category All	Responsible Party Human Resources
Category Independent Contractor	Sub-Category Foreign Persons	Responsible Party Individual engaging Independent Contractor
Category Material Transfer Agreement	Sub-Category Foreign Persons	Responsible Party Office of the Vice-President for Research (OVPR)
Category Memorandum of Understanding	Sub-Category Foreign Persons	Responsible Party Office of Global Affairs and OVPR
Category Non-Disclosure Agreement	Sub-Category Foreign Persons	Responsible Party OVPR
Category Other License Agreement	Sub-Category Foreign Persons	Responsible Party Procurement and OVPR
Category Sponsor	Sub-Category All**	Responsible Party OVPR
Category Subcontractor/Sub-recipient	Sub-Category All**	Responsible Party OVPR
Category Technical Service Provider	Sub-Category Foreign Persons	Responsible Party Procurement
Category Visitor	Sub-Category Foreign Persons	Responsible Party Individual hosting Visitor
Category Wire Payment	Sub-Category Foreign Persons	Responsible Party Accounts Payable

Exclusions

*Does not include: Current University employees.

*Does not include: Federal, state or local government authorities or agencies in the United States and their employees or other U.S. Institutions of Higher Education and their employees.

Research Foundation for SUNY Central Office Role

Provides the campus with licenses for the use of VC and conducts an annual batch screening** of the vendor file

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Return to the Guidance & Procedures for Export Control Compliance