Restricted Parties and High Risk Interactions | Research

Restricted Parties

Restricted Parties are entities or individuals considered to be of heightened concern or high-risk with respect to U.S. national security interests. There are various lists and tools available (for the screening and identification of Restricted Parties) many of which are established and maintained by the U.S. Government. Interaction with any Restricted Party may require additional export licenses and permits, for example, for information and items that are designated as EAR99, and as such, not listed on the Bureau of Industry and Security Commerce Control List (CCL). A careful review of any proposed transaction or activity with any Restricted Party is warranted.

Restricted Parties Screening

Prior to participating in a research collaboration, including any exchange of material or information; faculty, researchers, and staff at Michigan Tech should screen their collaborators (including people, academic institutions, governments, and companies) against the restricted parties lists. Screen for restricted parties before doing any of the following:

International research collaborations
Teaching courses abroad or online
Presenting at international conferences
Hosting international visitors
Exchanging materials, data, technical information, or money (screen recipients or sponsors)

For activities conducted according to University requirements for notification and approval, Restricted Party screening to identify restricted or high-risk entities and individuals is conducted by the University’s Research Security Office and other administrative offices as a part of the approval process for the listed activities/transactions:

Individuals and their current and past institutional affiliations including both:

visiting scholars, and
graduate students involved in, whether paid or unpaid, sponsored research activities subject to a foreign national restriction,

Foreign entities (including institutions, companies, and individuals) entering into contracts or agreements,
Foreign entities sharing or receiving technology,
Export-controlled purchases from foreign entities, and
Others, as otherwise required by law or University policy.

If desired, faculty, researchers, and staff may perform a restricted party screening pre-check early in their research planning by utilizing the Restricted Party lists and tools or by completing the International Collaboration Request form.

Entities and Individuals Identified as Restricted Parties

If screening results in the identification of a Restricted Party, the proposed interaction is either denied or will require further evaluation.

Denied Interaction

It is Michigan Tech’s policy to deny interaction with entities or individuals on the Denied Persons List or with members of the Seven Sons of National Defense Universities. As of June 2021, the Seven Sons of National Defense Universities are:

Beihang University,
Beijing Institute of Technology,
Harbin Engineering University,
Harbin Institute of Technology,
Nanjing University of Science and Technology,
Nanjing University of Aeronautics and Astronautics, and
Northwestern Polytechnical University.

High-risk Interaction

It is also Michigan Tech’s policy that an evaluation will be performed on a case-by-case basis for any proposed interactions with entities or individuals on any of the following lists:

U.S. Bureau of Industry and Security Entity List,
Export Administration Regulations Unverified List,
Australian Strategic Policies China Defence Universities Tracker,
Center for Security and Emerging Technology Chinese Talent Program Tracker,
Any other lists issued by the U.S. Departments of State, Commerce or Treasury, or any relevant federal entity.

Permitted interactions will be determined by the Export Control and the Senior Associate Vice President for Research Administration, with input from the Vice President for Research, Chief Information Security Office, Chief Research Security Officer, and Legal Counsel, as appropriate.

Requests for Reconsideration

Requests for reconsideration of a determination can be made to the Vice President for Research and Research Security team based on additional or new information obtained after the initial review. The request must be submitted by email within five (5) University business days of the initial determination and include a detailed description of the additional or new information. A written response via email will be sent within a time frame that allows for a thorough analysis of all available information and also accounts for time sensitive issues identified in the request for reconsideration.

Restricted Party Lists/Tools

There are multiple public lists/tools available to conduct restricted party screening, and include but are not limited to:

Denied Persons List

The Denied Persons List is a list of high-risk individuals and entities that have been denied export privileges by the U.S. Government.

Members of Seven Sons of National Defense Universities

The U.S. Government describes the ‘Seven Sons of National Defense’ as a group of leading Chinese universities with deep roots in the military and defense industry. The universities are all subordinate to the Ministry of Industry and Information Technology, which oversees China’s defense industry through its subordinate agency, State Administration for Science, Technology and Industry for National Defense (SASTIND).

Entity List

The Entity List identifies foreign parties that are prohibited from receiving any items subject to the EAR unless the exporter (Michigan Tech) secures a license. Parties on this list have been identified by the U.S. Government as presenting a greater risk of diversion of certain items contrary to U.S. national security and/or foreign policy interests.

Unverified List

The Unverified List is a list of parties that have not cooperated with the U.S. Government during post-shipment verification checks. The presence of a party on the Unverified List in a transaction is a “red flag” that must be resolved by the University before proceeding with the transaction.

Australian Strategic Policies Institute China Defence Universities Tracker

The China Defence Universities Tracker is a tool to inform universities, governments and scholars as they engage with the entities from the People’s Republic of China. Research for this tool focused on institutions for their military links, security links, or known connection to human rights abuses or espionage.

Center for Security and Emerging Technology Chinese Talent Program Tracker

The Chinese Talent Program Tracker is a catalog of Chinese Party-State-sponsored initiatives aimed at cultivating China’s domestic talent pool in support of China's strategic civilian and military goals. It resulted from analysis of primary Chinese sources publicly available on PRC ministry and government websites, state-owned media sources, and Chinese university websites. It is not meant to provide a comprehensive assessment of individual talent programs. Rather, it aims to make this information more accessible to the general public so they can have a better understanding of the depth and breadth of China’s talent initiatives.

Nonproliferation Sanctions enacted through any applicable executive order, federal policy, or statute

National Security Presidential Memorandum – 33