Entity List and Unverified List (U.S. Commerce Department)
The Entity List catalogs over 1,000 people and organizations throughout the world for which more stringent export control restrictions are imposed. Even if an item may typically be exported to a particular country, that same item may not be permitted to be exported to a recipient in that country that is on the Entity List.
If the Commerce Department cannot verify information for a person or organization, they may place it on the Unverified List. Collaborations with people or organizations on the Unverified List should be treated the same as collaborations with Entity List people or organizations.
Identifying Entity List People and Organizations
MIT Export Control can screen your potential collaborators against the Entity List and other pertinent government watch lists in advance, and advise you of related risks.
Collaborating with Entity List People and Organizations
A fundamental research collaboration with an entity or individual on the Entity List is lawful, although there are restrictions on interactions and each such collaboration should be considered on a project-by-project basis. When collaborating with an entity or individual on the Entity List:
- Consult MIT Export Control early to learn about project restrictions.
- Do not ship or transfer any tangible physical items (this includes commercially-available goods as well as physical items that you create as part of research) to an Entity List institution.
- Except for publicly available information or the results of fundamental research, do not furnish software, technical information, or research reports to an Entity List institution.
Specially Designated Nationals (SDN) (U.S. Treasury Department)
The SDN list contains names of individuals and entities targeted for special sanctions by the U.S. government. Typically, these include terrorists, drug traffickers, and state-controlled entities of sanctioned governments, among others, but the list also includes some universities and research institutes.
Identifying People and Organizations on the SDN List
The export control team can also screen your potential collaborators against the SDN list and other pertinent government watch lists in advance, and advise you of related risks.
Collaborating with People and Organizations on the SDN List
You cannot collaborate or otherwise engage with an individual or entity on the SDN list unless you receive a specific license from the U.S. government. A license from the U.S. government to engage with an SDN is difficult to obtain and often requires several months of governmental review. If you have engaged with, or seek to engage with, someone on the SDN list, you must contact MIT Export Control for further guidance.
Updated November 25, 2024