Restricted Party/ Denied Entity FAQs

This is too broad to comprehensively cover in an FAQ, 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 You cannot send (mail, fax, email) items (i.e., materials, substances, equipment, technical data, and unpublished data) to a denied entity without an export control license.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. Collaborating with restricted entities on a federally funded project is likely prohibited by the award language and could also impact your 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).

• 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 updated its most restricted list – the DOD 1286 List on June 24, 2025. 
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.

From an export control perspective, denied entities:

• 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.
• The U.S. government may occasionally grant visas for individuals who are affiliated with a denied entity or 1286 entity. If a visitor affiliated with a denied entity or 1286 entity is in the U.S. on a valid visa, you may generally collaborate with the individual on fundamental research. But the visitor cannot share items (data, equipment, materials, anything) with a denied entity (i.e., their affiliated institution). If the visitor returns to a denied or 1286 entity institution or leaves the U.S. and remains affiliated with the denied entity, you cannot collaborate with them without a license.
• In addition, the visitor may not be able to work on federally funded projects and collaborating with them including publishing papers may impact your future federal funding. The federal government has various risk matrices for federal researchers and one of the high-risk indicators is collaborating with restricted parties. Some awards may have prohibitions in the award terms.
• In addition, working with or collaborating with a person associated with a denied or 1286 entity is an extremely high risk from a foreign influence perspective. It may negatively impact your future federal funding, particularly with the DoD. However, you will want to make sure you properly disclose any affiliations as under reporting this information can be problematic and violate federal law.

• 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

• 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