Restricted Party Screening Guidance and Procedures
Various U.S. government agencies maintain lists of individuals, companies, and organizations, both foreign and domestic, whose U.S. export privileges have been blocked, restricted, or revoked. To remain compliant with the regulations, the University of Arizona must ensure that no transactions are conducted with such parties unless authorized by the listing U.S. government agency.
The University of Arizona uses a web-based software tool known as Visual Compliance to quickly and easily conduct screenings against the various Restricted Party Screening, Denied Party Screening, as well as Blocked, Unverified, and Sanctioned Party Screening lists. Screenings should be completed for:
- Foreign and domestic sponsors and vendors
- Foreign research collaborators
- All personnel associated with export controlled research
- Foreign visiting scientists and Designated Campus Colleagues (DCCs)
The University Export Control Program (UECP) manages user access to Visual Compliance. University of Arizona employees with a need to conduct screenings can access Visual Compliance by sending a request to the UECP at email@example.com. In the email, include your
- job title
- work address
- college and department
- phone number
The UECP will create a user account and send you a temporary password with instructions on how to access the Visual Compliance system and change your temporary password. UECP will also send you a Code of Conduct form, instructions on how to conduct a screening, review the results, and steps to take if you receive a "hit" or match. The Code of Conduct form should be signed and returned to UECP as soon as possible.
Once an account has been established, a training session with UECP can be scheduled. Registered users may also watch the Visual Compliance online training modules by selecting the training icon at the bottom of the screen after logging in to the site at www.visualcompliance.com. Visual Compliance also conducts quarterly training sessions on system updates and best practices and sends email notifications of training dates and times to all registered users.
Although training is not required prior to using Visual Compliance, UECP recommends that you complete the training as it provides a more complete understanding of how to screen and review the results.
Visual Compliance Best Practices and Procedures
Individual and Company Screening searches for the name of an individual or a company against government restricted party lists. The manual entry of the names of individuals or companies and the selection of search parameters determine the results, which can vary widely depending on those selections.
Using both the name and company fields for a search does not perform two searches at once. Screening the name of the individual and the company should be completed as separate screens.
- Go to www.visualcompliance.com.
- Log in using your log in (email address) and password that you created. You will then come to a main menu screen. Select “RESTRICTED PARTY SCREENING”.
- Enter the full name of the person you are screening in the Name field or the entire name of the institution/company (e.g. vendor, sponsor, or collaborator) in the Company field. It is not necessary to enter the full address for the party being screened, however it is recommended to enter city, state, and/or country.
- Using the drop down arrow in the Comment box, select the most appropriate explanation for conducting the screening. Enter a brief description of the purpose of the screening in the box (e.g. service agreement, award). This information will appear on the screening result for record keeping and reference purposes to the screener.
- Below the comment box are the search parameters. Select the Fuzzy level radio button below the comment boxes and select “2” from the drop down box (Our standard procedure is to screen parties using the “Fuzzy Level 2” criteria). The Fuzzy Level search will ensure a more comprehensive screening because it looks for words with letters that resemble those searched, compensating for minor spelling errors.
- Make sure the other radio buttons are selected on the screen:
- Stemming: Adjusts for word endings (e.g. –ed, -ing), returning results containing the “root” of the word
- Thesaurus: Accounts for variations in form and style for geographic place names (e.g. UK, United Kingdom) and possible variations of proper names (e.g. Bob, Robert, Bobby)
- Field Specific: Prevents name and company keywords from being searched in the “Notes” field
- Remove business endings and abbreviations: Strips business declarations
- Export, Police, Sanctions, PEP, GSA, and International: Are the group of lists you will be screening against. The University of Arizona default is to have all of these checked.
- Once all information has been entered (e.g., name or company, comment information, fuzzy level 2 selected), click the “Screen” button to conduct the screening.
- A result screen will immediately appear. The Visual Compliance System allows you to either email the result or print it for auditing/record keeping purposes.
The result screen will either display a “NO MATCHING RECORDS FOUND” result or a listing of any matching records.
- Each matching record will have a reference number that serves as a direct link to detailed information about the specific match found, including the list on which the name appears and the reason for the restriction.
- Alert levels indicate the number of fields found in the Restricted Party Screening (RPS) database matching the keywords supplied in the search criteria.
- The more search criteria fields supplied with keywords for the search the higher the alert level. As in the example below, the fuzzy search resulted in only one potential match on the name “Boeing” and therefore, the alert level is one.
If you receive a "hit' or match on the person or entity
- Do an “exact” search using the full name. If you still receive a hit from Visual Compliance (VC), compare the physical addresses (i.e., if you know the person is from the United Kingdom, and you have a hit which says the person is from California, it is probably not the same person). If no location is listed or the locations are the same, look at the birthday of the person screened and compare.
- If you receive a re-screening “hit” notice from VC, look at the comment section as a reminder as to why the person/entity was initially screened. Also compare the name you initially screened against the names of the “hits” that VC lists below the screen. Because VC screens at a high “fuzzy” level, it is not uncommon for several names to be listed. Typically, most of the names listed will only include a portion of the name that was originally screened, i.e., not a “hit”.
- Notify University Export Control Program of a true “hit”or if you need assistance in making a determination (firstname.lastname@example.org).
- The University Export Control Program will verify any positive “hits” by contacting Visual Compliance and the appropriate agency list.
- No payments should be given to or contracts signed with any person or entity positively identified on one of the lists until it has been cleared through the University Export Compliance Program (a license may be required or, in fact, could be denied).
- If the “hit” is verified and the University has already conducted transactions with that person or entity, the University Export Control Program (UECP) will notify Research, Discovery & Innovation and the Office of the General Counsel.
- At that point a determination will be made as to the next course of action which could include filing a disclosure of a violation to the agency that maintains the list and removing the individual from a project (if applicable).
Please contact the Export Control Program at email@example.com or (520) 626-2437.