Under federal export control regulations, U.S. citizens may not engage with certain foreign entities, including foreign persons, academic institutions, governments, companies, or other foreign entities, and these are referred to as Restricted Parties. This means that MIT researchers are not able to interact with these Restricted Parties, including through research or other collaborations, business interactions, sending tangible items to or on behalf of the restricted entity, providing technology or software to the restricted entity, or even just providing the restricted entity with a service. As a reminder, these regulations apply to Outside Professional Activities as well, including consulting and adjunct professorships.
To help meet this federal compliance obligation, MIT subscribes to Restricted Party Screening, a tool that allows people within the MIT domain to screen potential foreign collaborators and to determine whether MIT researchers may engage with the entity. MIT has a university-wide license to a program called Visual Compliance that faculty and staff should use to perform Restricted Party Screening in the following instances:
- Before initiating a formal or informal collaborations
- Before discussing plans to engage in sponsored programs
- Before exchanging personnel, materials, data, confidential information, or money with foreign persons, academic institutions, governments, companies, or other foreign entities.
- Before considering research collaborations or appointments
This Restricted Screening Party tool screens fifty lists kept by the U.S. Government. If you enter a name or company in your search and there is a matching record, it could mean that MIT cannot do business with this party or it could mean that the party is a foreign dignitary or the entity (institution or company) is state-owned. This is why it is important to contact MIT Export Control so that we can determine the extent of the restrictions and next steps.
You must register at the Visual Compliance website to begin using the program.
If Visual Compliance [website] identifies a match, it means that the foreign person or entity you screened is a restricted party or the software identified a false positive. Do not proceed with the foreign collaboration or other activity until you contact MIT Export Control at email@example.com to interpret your search results.
Contact the MIT Export Control Compliance Team at firstname.lastname@example.org, or by phone at 617-253-2762 (Janet Johnston).