The procedures outlined below, Restricted Party Screenings and Restricted Party Lists, Export Controls Reviews, and Embargoed Country Screenings, are incorporated into the University of Pittsburgh's Academic Visitor vetting and record-keeping process (the MyEC system). This process uses industry best practices in order to determine whether a prospective Visitor's potential affiliations or research interests, or both, should be reviewed further. The rationale behind the procedures is provided below. Information on how these procedures are embedded in the MyEC system and use of the system is delivered on the Hosting Visitors page under Step 2: Visitor Screening and Export Controls Review and Visit-Related Training respectively.
Visitor Vetting and the MyEC System
- Restricted Party Screenings and Restricted Party Lists
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U.S. government agencies and U.S. allies maintain public lists of individuals and entities, which are restricted or prohibited from participating in certain types of transactions with U.S. persons (defined as U.S. citizens and permanent residents or any corporation, business, organization, or group incorporated in the U.S. under U.S. law). Individuals and entities can be placed on these public lists (i.e., restricted party lists) for multiple reasons ranging from tax evasion to terrorism. These lists include both domestic and international individuals and entities.
Restricted party screenings (RPS) check against the aforementioned lists and are necessary in order to rule out possible restrictions or prohibitions on prospective Academic Visitors and their sponsors. This short step also ensures that the University of Pittsburgh and the sponsoring school or department do not unknowingly violate the law. RPS are required for all Category 2 and 3 Visitors and their affiliated institution, company, or sponsor, and are conducted automatically via the MyEC electronic review process. RPS are recommended for Category 1 Visitors and their affiliated institution, company, and sponsor.
- Export Controls Review
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Export controls include U.S. laws and other regulations that involve the shipment, transfer, or disclosure of controlled items, technical data, and software to foreign countries or to foreign persons and entities within the U.S. These laws aim to protect the national security, economic interests, and foreign policy of the United States. The information requested via the MyEC electronic review process is reviewed by the Office of Trade Compliance in order to determine whether any government licenses or other internal controls are needed for a prospective Visitor to engage in the planned activities.
- Embargoed Country Screening
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Certain organizations and individuals are subject to trade sanctions, embargoes, and other restrictions under U.S. law. If your prospective Academic Visitor is a citizen of an embargoed country, or their sponsoring institution is located in an embargoed country, a high probability exists that a specific government license and/or an internal control plan will be required in order for the University to host the Visitor.
Currently, the U.S. Department of the Treasury lists the following countries as highly embargoed: the Crimea Region of Ukraine, Cuba, Iran, North Korea, and Syria. The University can host a Visitor from an embargoed country who is in the U.S. on an approved visa, but a review of the Visitor's planned activities will be required first to determine if a specific government license is required.
The MyEC electronic review process automatically checks via the restricted party screening (RPS) whether a potential Visitor hails from an embargoed country for any category of Visitor entered into the system. Contact the Visitor Liaison for advice if the MyEC system is not used for a Category 1 Visitor, and an embargoed country is an element of a proposed Category 1 visit.