Restricted Party Screening at Penn

U.S. government agencies maintain lists of individuals and entities, both in the United States and abroad, that have committed export violations or other offenses. Financial dealings and other transactions with, or providing a service to, such restricted parties are prohibited without a license or other approval from the applicable government agency. Restricted party screening is recommended depending on the transaction involved.

Penn has systems in place to ensure that restricted party screening (RPS) occurs for certain international transactions and activities, such as the Research Inventory System (RIS) and eShip@Penn^®.

Penn does not have an automated system in place for screening:

• International Students and Scholars
• Other international visitors (e.g., visitors touring Penn research labs or facilities)
• International collaborators or activities not managed through Penn systems

Screening the individuals and institutions before an official invitation is offered, or the activity takes place, can help identify any issues of concern.

• International students and scholars and their home institutions should be screened before beginning the visa application process or entering into any agreement with the home institution.
• Other international visitors and their home institution should be screened well in advance of travel to Penn and before providing access to labs or facilities.
• International collaborators or activities not captured in RIS should be screened before beginning your collaboration and well in advance of any travel.

Being on a restricted party list does not necessarily mean an individual can’t participate in activities at or with Penn, but it does mean that we should take a closer look at the reason for the inclusion on a list, the activities/research the individual is expected to perform, and whether or not Penn is able and willing to comply with any restrictions such participation would entail.

Penn utilizes Visual Compliance for restricted party screening. Anyone with a upenn.edu email address can register for access by taking Penn’s online Visual Compliance training.