Why do we conduct screenings?
Individuals participating in international research and other university business must engage with domestic and international partners. Various U.S. government agencies maintain lists of individuals, companies, and organizations (foreign and domestic) whose U.S. export privileges have been blocked, restricted, or revoked, as well as entities or persons under embargoes or sanctions. These are known as “restricted parties.” Under the regulations, Northwestern may not engage in transactions with a restricted party on a U.S. entity list or U.S. sanctioned list without prior government approval. Restricted Party Screenings (RPS) are a part of Northwestern’s due diligence process. There are also many prohibited or proscribed lists with restrictions related more broadly to research security and foreign influence.
Who should be screened?
Restricted party screenings should be conducted for, but not limited to the following:
- Research Visitors
- Vendors
- Sponsored Research Collaborators
- Gifts
- Corporate/Industry Partners
- Hazardous Shipments
- All Other Shipments Abroad
- International Research Collaborations
- Teaching Courses Abroad
- Presenting at International Conferences
- Hosting Other International Visitors
- Other International Collaborations
How can you request Restricted Party Screenings for your collaborators?
Screening is an easy and quick process and will identify if a person or organization is on a U.S. restricted list. You can email the ECIC team directly to conduct your screening. Alternatively, you can have your own account if you anticipate ongoing screening needs. Reach out to our team; we can set up individual logins for users and provide training. See Visual Compliance Standard Operating Procedures
What are examples of key restricted lists (note: the below list is not exhaustive)?
- DOD 1286 list is one of the most problematic lists. The 1286 List includes foreign institutions that have been confirmed as engaging in problematic activity as described in Section 1286(c)(8)(A)of the NDAA for FY 2019. The DOD published an update to its most restricted list – the DOD 1286 List on July 23, 2026. This list can impact researchers with federal funding from any agency, not just the DOD.
- Do not engage in collaborations involving individuals affiliated with a DOD 1286 entity or any restricted entity on federally funded research. Contact the ECIC before initiating any potential collaboration with a DOD 1286-affiliated individual, even if the collaboration is not related to a federally sponsored project.
Find more information here.
- BIS Entity List The Bureau of Industry and Security (BIS) publishes the names of foreign persons – including entities (businesses, research institutions, government, and private organizations) and individuals, that are subject to specific license requirements for the export, reexport and/or transfer (in-country) of specified items. These persons comprise the Entity List (ELT), which is found on Supplement No. 4 to Part 744 of the Export Administration Regulations (EAR). Entities included on this list are referred to as denied entities.
- Australian Unitracker: The “Unitracker” is not a denied entity list per se, it is a list compiled by an Australian think tank with funding from the U.S. State Department’s Global Engagement Center. In some instances, but not all, Australian entities may eventually appear on a U.S. government-denied list.
What does it mean to show up on a restricted list?
From an export control or research security perspective, restricted entities:
- Generally require a federal license to share (ship, mail, or transfer) anything with a denied entity or 1286 entity. There is also a presumption of denial – the U.S. government will almost certainly deny the license.
- Northwestern will not routinely sponsor Research Visitors, including interns, from U.S. restricted lists if the person themselves is on a U.S. restricted list or their home institution/employer/funder is on a U.S. restricted list. There is a limited appeal/waiver process for certain instances. Learn more here.
- If a former NU student, postdoctoral researcher, or visitor becomes affiliated with a denied entity, a Section 1286 entity, or another restricted party after leaving the United States, collaboration with that individual generally requires prior U.S. government authorization, such as an export license or other federal approval.
- Working with or collaborating with a person associated with a denied or 1286 entity or other restricted party is an extremely high risk from a foreign influence perspective and may violate federal law or your award terms. It may negatively impact your future federal funding. However, you will want to make sure you properly disclose any affiliations as under reporting this information can be problematic and violate federal law.
What happens if you are associated or affiliated with a restricted party?
Every situation is different, so please immediately contact the
ECIC for a consultation and guidance.
Can you collaborate with an organization on the Australian Unitracker?
Generally speaking you may collaborate with entities that are
only on the Australian Unitracker (i.e., they are not also on a U.S. restricted list). However, you need to be mindful when
shipping or sending anything outside the United States. In addition, collaborations need to be reported to federal agencies. Any collaboration with a person associated with any university or organization from a country of concern (China, Iran, North Korea, and Russia) may
likely impact your risk profile even if it's not on a restricted list.
What should you do if you are midstream on a collaboration with a restricted party?
As soon as possible, discuss the situation with the
ECIC. There are research integrity considerations, in addition to research security concerns (malign foreign influence, risk profile impact, etc.). For example, we do not advise that you simply take someone’s name off a potential publication. This could trigger research integrity issues and be perceived by federal funding agencies as concealing a foreign collaborator. However, do not send anything to the restricted entity if they are located outside the country as it may need an export control license. You
may be able to finish the manuscript without violating export control law, but please discuss with the ECIC office before moving forward.
When a collaborator is from a restricted entity, what can you do with them?
Generally very little but this depends on the list and the applicable restrictions under the regulations. Contact the ECIC for specific guidance. You cannot send (mail, fax, email) items (i.e., materials, substances, equipment, technical data, and unpublished data) to a denied entity without an export control license. However, the federal government will very likely deny the license request (i.e., there is a presumption of denial).
Collaborating with an individual that is from a restricted entity – particularly if located in a country of concern (China, Iran, North Korea, and Russia) – is extremely high risk.
Collaboration with restricted entities or parties on federally funded projects is generally prohibited under U.S. government regulations. In addition, collaborations outside the scope of federally funded projects may still pose compliance concerns and could affect eligibility for future funding. At minimum, you will likely be asked to submit to a mitigation plan (e.g., reporting international travel in advance, participating in research security training, and/or possibly agreeing not to collaborate with any individual from countries of concern during the award period).
Can I provide feedback on a paper initiated and led by a person from a restricted entity?
This is an individual decision that should be based on a careful assessment of both the potential benefits and risks, unless you have certified, through a mitigation plan or research security certification, that you will not collaborate with restricted entities. Consider the following questions:
- What is the benefit to you and to Northwestern?
- Is there any overlap with your federally funded research or other federally sponsored activities?
- Would you be listed as a co-author or otherwise formally associated with the work?
Depending on the answers, the proposed activity may increase your risk profile with federal funding agencies and could raise research security or compliance concerns.
Should I accept travel reimbursement or funding from a restricted party?
Consult with the ECIC team, but generally speaking the answer is “no.” Doing so may be a violation of federal law and will almost certainly raise your risk profile with federal funding agencies. You cannot pay a restricted entity or party without advanced federal authorization (e.g., a license or license exception).
What criteria do federal agencies use to assess a researcher’s security risk profile?
Several federal funding agencies (DOD, DOE, NIH, NSF) have published information on how they assess certain international risk factors, and which factors may warrant mitigation or impact funding opportunities. These matrices provide insight into what specific international activities bear risk to the agencies and to what degree. The risk criteria differs by each agency, so it is important to review guidance from the agencies you work with or hope to work with carefully. However, common areas of concern include but are not limited to foreign talent plan participation; foreign funding (disclosed and undisclosed), positions, affiliations, and associations with foreign countries of concern (FCOC - China including Hong Kong and Macau, Iran, North Korea, and Russia); collaborations with restricted parties or denied entities; foreign patents; and co-authorships with FCOC for some agencies, etc. Learn more here. What do you need to disclose in your Northwestern Conflict of Interest disclosure?
- All foreign and domestic Significant Financial Interests (e.g., payments, equity, reimbursed travel);
- All external positions and appointments (e.g., board service, visiting or honorary appointments, serving as a PI or teaching outside
- Any research support that did not go through Sponsored Research or Alumni Relations and Development
- Any participation in a foreign talent recruitment program, malign or otherwise
Disclosure is required in
eDisclosure within 30 days of acquiring or becoming aware of a new relationship or financial interest for all agencies except the DOE which requires it within 15 days. More information can be found in the
Policy on Conflict of Interest in Research.What do you need to disclose to funding agencies?
- All foreign and domestic academic, professional, and institutional positions and appointments must be included in your biosketch per agency requirements
- All current and pending support, including grants, contracts, agreements, in-kind support, and external support for students and postdoctoral fellows
- Any research performed outside of Northwestern (e.g., via consulting or other appointments)
- Any participation in programs sponsored by foreign governments, instrumentalities, or entities, including talent recruitment programs must be listed in your Current & Pending Support
- And much more depending on the agency guidance including but not limited to your collaborators and co-authors and their affiliated institutions.
- See this resource maintained by Sponsored Research for detailed guidance.
What is a Foreign Talent Recruitment Program and a Malign Talent Recruitment Program?
Definitions can be found on the
Research Security website. If you are receiving compensation (of any kind – monetary or non-monetary including honorariums) from a designated country of concern (China including Hong Kong and Macau, Iran, North Korea, or Russia) review this
resource and reach out to the
ECIC.What has changed?
You cannot be a Malign Foreign Talent Recruitment Program participant and apply for or receive federal funding. The federal government broadened the foreign talent plan definitions (malign and non-malign) and has prohibited participation in Malign Foreign Talent Recruitment Programs if you receive federal funding. Northwestern implemented these changes and prohibition by updating the
Policy on Conflict of Interest in Research in January 2024.
Where can I learn more?
To assist employees in navigating international partnerships and avoiding inadvertent issues, the Office for Research maintains a
webpage with guidance on improper foreign influence.