Ethics, Compliance and Audit Services
Working with Restricted Entities
The U.S. government restricts sharing non-public information or shipping to certain individuals or organizations for economic and national security reasons. Certain transactions with restricted entities may be permitted with an export license. Location Export Control Officers are available to help make a license determination for:
- Foreign collaborations (including visitors or visiting scholars)
- International shipments
- Paying foreign persons or entities (for purchases, travel, reimbursement, etc.)
- Agreements with foreign entities
What are Restricted Entities?
The U.S. government maintains a number of lists of federally sanctioned, debarred or restricted persons and organizations such as:
- The Specially Designated Nationals and Blocked Persons List (U.S. Department of Treasury);
- The Foreign Sanctions Evaders List (U.S. Department of Treasury);
- The Entity List (U.S. Department of Commerce);
- The Denied Persons List (U.S. Department of Commerce);
- The Unverified List (U.S. Department of Commerce);
- The Nonproliferation Sanctions List (U.S. Department of State);
- The AECA Debarred List (U.S. Department of State).
When considering whether or not a transfer of items or disclosure of information will require an export license, the following aspects are reviewed:
- What is being transferred or disclosed
- Who and where it is going or who it is being disclosed to
- Whether the destination or receiving location, individual or recipient is a restricted entity
University of California faculty and staff have access to Visual Compliance software which combines these government lists into one easy screening tool. Click here to sign up for this tool. Or contact your location Export Control Officer for assistance. If you determine that your activity involves an entity on one of these federal lists, please contact your location Export Control Officer for assistance.
If an export license is required, it takes a minimum of 6 weeks to have it approved by the U.S. government and must be in place prior to the export or disclosure. Noncompliance with the export regulations can result in penalties of $250,000 to $1 million per violation.