DRAFT
Research Compliance  /  Compliance  /  Export Compliance  /  Sanctions and Embargoes  /  Restricted Party Screening

Restricted Party Screening

Updated April 4, 2022

Guidance and Information

Universities or Institutions on Entity or Unverified List

Institute collaborations with Restricted Parties (RPS), including some universities, can raise "red flags" with government agencies. The persons and entities on the RPS Lists are subject to prohibitions and individual licensing requirements. It is recommended that you check the RPS Lists to determine if your collaboration may involve a party of concern. The lists are comprised of names of certain persons, businesses, research institutions, government and private organizations that are published by the Bureau of Industry and Security, Department and Office of Foreign Assets Controls.

The parties on the list below are prohibited from receiving items that are subject to the export control regulations without an export license. In some cases, there is a presumption of denial by the cognizant government agency. Not all engagements with RPS listed entities will result in a prohibited activity. However, the nature of the proposed collaboration needs to be reviewed because some entities are subject to higher levels of control than others or have a presumption of denial by the cognizant government agency.

The list on this page was generated on April 1st, 2022. The government agencies revise and correct the entries on the Entity Lists on a regular basis; in order to ensure that each entry reflects the most accurate and recent information for the person named in that entry, it is recommended that you check the live lists of entities in the links provided here.

What is the Entity List?

The Entity List contains the names of individuals and organizations that have engaged in activities of concern to the U.S. Government. The Bureau of Industry and Security (BIS) publishes the names of certain foreign persons – including businesses, research institutions, government and private organizations, individuals -- that are subject to specific license requirements for the export, reexport and/or transfer (in-country) of specified items. BIS recommends that exporters exercise a high level of due diligence prior to entering into a transaction with any person on the Entity List, regardless of where that person is located. BIS maintains three lists: the Denied Persons List (DPL); the Unverified List; and the Entity List.

Entity List

The Entity List can be found here (use "CTRL F" to search the entity or party.)

Entity List Name Entity List Address Effective Date of Listing
Beijing University of Aeronautics
and Astronautics (BUAA), a.k.a., the following alias:

• Beihang University
37 Xueyuan Road, Haidan District,
Beijing
05/14/01
Northwestern Polytechnical
University, a.k.a., the following three aliases:

• Northwestern Polytechnic University
• Northwest Polytechnic University
• Northwest Polytechnical University
127 Yonyi Xilu, Xi’an 71002
Shaanxi, China

Youyi Xi Lu, Xi’an, Shaanxi, China

No. 1 Bianjia Cun, Xi’an; and West Friendship Rd. 59, Xi’an

3 10 W Apt 3, Xi’an
05/14/01
Higher Institute of Applied
Science and Technology (HIAST), a.k.a., Institut Superieur des Sciences
Appliquées et de Technologie (ISSAT), Institut des Sciences Appliquées et de
Technologie
P.O. Box 31983
Barzeh, Damascus, Syria
03/10/05
Sichuan University No. 24 South Section 1, Yihuan Road, Chengdu, China,
610065

No. 29 Jiuyanqiao Wangjiang Road, Chengdu, China,610064

People’s South Road, Chengdu, China, 610041

Shuangliu County, Chuanda Road, Chengdu, China, 610207
09/19/12
University of Electronic Science
and Technology of China
No. 4, 2nd Section, North Jianshe
Road, Chengdu, 610054
09/19/12
National Supercomputing Center
Guangzhou (NSCCGZ)
Sun Yat-Sen University,
University City, Guangzhou, China
02/18/15
National University of Defense
Technology (NUDT), a.k.a., the following one alias:

• Hunan Guofang Keji University.
Garden Road (Metro West), Changsha City, Kaifu
District, Hunan Province, China

109 Deya Road, Kaifu District, Changsha City, Hunan Province, China

47 Deya Road, Kaifu District, Changsha City, Hunan Province, China

147 Deya Road, Kaifu District, Changsha City, Hunan Province, China

47 Yanwachi, Kaifu District, Changsha, Hunan, China
02/18/15
Xinjiang Police College Xinshi District, Changsha Road,
No. 1108, Urumqi, Xinjiang, China
10/09/19
Beijing Computational Science
Research Center, a.k.a., the following three aliases:

• BCSRC;
• Beijing Computing Science Research Center; and
• CRSC
Bldg. 9 East Zone, ZPark II No. 10 East Xibeiwang
Road, Beijing, China

Building 9, East District,

Zhongguancun Software Park, No. 10, Northwest Wangdong Road,
Haidian District, Beijing, China
06/05/20
Harbin Engineering University No. 145 South Tongda Street,
Harbin, Heilongjiang Province, China 150001
06/05/20
Harbin Institute of Technology No. 92 Xidazhi Street, Nangang District, Harbin,
Heilongjiang, China

No. 92 West Dazhi Street, Nangang District, Harbin, Heilongjiang, China

No. 2 West Wenhua Road, Weihai, Shandong, China

Pingshan 1st Road, Shenzhen, Guangdong, China
06/05/20
Beijing Institute of Technology No. 5 South Zhongguancun Street,
Haidian District, Beijing, China
12/21/20
Beijing University of Posts and
Telecommunications (BUPT)
No. 10 Xitucheng Rd, Haidian District Beijing 100876,
China
12/21/20
Nanjing University of Aeronautics
and Astronautics
No. 29 Yudao Street, Nanjing,
Jiangsu

No. 29 Jiangjun Avenue, Jiangning District, Nanjing, Jiangsu

No. 29 Binhe East Road, Liyang, Jiangsu
12/21/20
Nanjing University of Science and
Technology
No. 200 Xiaolingwei Street, Xuanwu District, Nanjing,
Jiangsu

No. 89 Wenlan Road, Qixia District, Nanjing, Jiangsu
12/21/20
Tianjin University No. 92 Weijin Road, Tianjin,
China 300072
12/21/20
Hefei National Laboratory for
Physical Sciences at Microscale (part of the University of Science and
Technology of China)
No. 96, Jinzhai Road, University of Science &
Technology of China, Hefei, Anhui, 230026 China
11/26/21
Moscow Institute of Physics and
Technology
Dolgoprudny Campus: 9
Institutskiy per., Dolgoprudny, Moscow Region 141701, Russia

Zhukovsky Campus: Ulitsa Gagarina 16, Zhukovsky, Moscow Region 140180, Russia

Moscow Campus 1 Stroyeniye 1, Klimentovsky Pereulok, Moscow Region 115184,
Russia
02/24/22

Unverified List

The Unverified List can be found here (use "CTRL F" to search the entity or party.)

Unverified List Name Unverified List Address Effective Date of Listing
Nanchang University No. 999 Xuefu Avenue, Honggutan
New District, Nanchang, 330031, China
05/17/18
Anhui Institute of Metrology No. 13, Yanan Road, Baohe Industrial Development
District, Hefei, China 230051
04/11/19
Guangdong University of
Technology
No 100 Waihuan Xi Road, Guangzhou
Higher Education Mega Ctr, Guangzhou, China 510006
04/11/19
Hefei Institutes of Physical
Science, Chinese Academy of Sciences
No. 350, Shushanhu Rd, Shushan District, Hefei City,
China 230031
04/11/19
Shanghai Institute of Applied
Physics, Chinese Academy of Sciences
239 Zhangheng Road, Pudong
District, Shanghai, China
04/11/19
Sun Yat-Sen University No. 135 Xingang, Xi Road, Guangzhou, China 10/08/20
Hunan University, State Key Lab
of Chemo/Biosensing & Chemometrics
Lushan Road, Yuelu District,
Changsha, Hunan Province, China
02/08/22
Southern University of Science
and Technology, Department of Mechanical and Energy Engineering
1088 Xueyuan Ave., Nanshan District, Shenzhen,
Guangdong 518055, China
02/08/22
Southern University of Science
and Technology, Department of Mechanical and Energy Engineering
1088 Xueyuan Ave., Nanshan
District, Shenzhen, Guangdong 518055, China
02/08/22

Denied Party List

The DPL lists persons that have been denied export privileges; any dealings with persons listed on the DPL that violate the terms of their denial order would be a violation of the EAR. The DPL can be found here.

Frequently Asked Questions

The Entity List was initially published by BIS in February 1997 as part of its efforts to inform the public of entities that have engaged in activities that could result in an increased risk of the diversion of exported, reexported or transferred (in-country) items to weapons of mass destruction (WMD) programs. Since its initial publication, however, grounds for inclusion on the Entity List have expanded to activities sanctioned by other agencies such as the State Department and Treasury that involve activities contrary to U.S. national security and/or foreign policy interests.

You should check the Entity List because exports, reexports, and/or transfers (in-country) to those persons named on the Entity List are subject to licensing requirements and policies. BIS recommends that "exporters screen the parties to transactions against the Entity List as a standard part of pre-transaction due diligence activities. Failure to conduct due diligence could result in criminal and/or civil penalties."

While some activities are allowed, BIS considers that "transactions of any nature with listed entities carry a "red flag" and recommends that U.S. universities proceed with caution with respect to such transactions."

Information resulting from fundamental research is not subject to the EAR. However, it is recommended that you seek OEC's guidance to review whether your collaboration remains limited to "fundamental research" activities, as defined in the regulations, and whether it will be subject to the Entity List's licensing requirements and policies.

Employees of persons on the Entity List are subject to the licensing requirements and policies specific to their employer. Therefore, in the case of universities on the Entity List, employees of the universities are subject to the same licensing policy and requirements that the universities are. This also applies to officers, trustees, and other persons in a similar position with the university. Please seek OEC review.

In some instances, yes. However, BIS considers "previous employment at any organization on the Entity List a "red flag" and recommends an additional level of due diligence before proceeding with the hiring process."

It depends on what you want to donate, whether the donation requires a license for the export, reexport, or transfer of that item to the university (as specified in the Entity List), and whether BIS approves your license application.

In addition to the Departments of Commerce, the State, and Treasury maintain separate lists for the programs each agency administers because these programs have different purposes and are regulated under different authorities.

Their lists should also be consulted before exporting, reexporting, transferring item(s), or financial transactions. These lists include the Specially Designated Nationals and Blocked Persons (SDN) List, the Debarred List, and the lists of persons subject to Nonproliferation Sanctions.

A consolidated version of all of the U.S. Government proscribed parties lists is available here.

Please contact Adilia F. Koch, Director Office of Export Compliance, adilia.koch@caltech.edu, if you anticipate your collaboration will involve an entity of concern or if you wish to screen multiple parties.