Departments have flexibility in how they purchase goods and services, but restricted party screening is an essential step when working with foreign vendors.
A screening ensures the university does not unintentionally do business with individuals or organizations flagged by the U.S. government for national security, sanctions, export control, or compliance concerns.
Why Screening Matters
- Avoids prohibited transactions
Many foreign entities appear on federal restricted‑party lists. Doing business with them may be prohibited or require a license before engaging in a business transaction. - Prevents penalties
Purchasing from a restricted entity, even unintentionally, can result in civil and/or criminal penalties. - Ensures export control compliance
Certain technologies, software, or equipment may require a license if the vendor is on a restricted list. Screening identifies these issues early. - Reduces project delays
Discovering a restriction after a purchase is made can halt a project, delay deliveries, or require cancellation of an order.
Purchasing Through Purchasing and Contracting Services
The Office of Export Controls screens all foreign counterparties on agreements processed through Purchasing and Contracting Services (PCS). Departments using PCS do not need to take additional steps.
Purchasing Directly From Foreign Vendors
Many departments make purchases outside PCS. In these cases, a restricted party screening is still required.
Before purchasing from a foreign vendor, request a compliance check from the Office of Export Controls.