|Restricted-Party Screening Reminder
This would typically depend upon the subject-matter focus of your activity, the persons with whom you are exchanging such subject matter, the countries that such persons are from or in, and/or what such persons are expected to do with the things or information that you share with them. We recommend that you explore this site to learn more about export controls and economic sanctions. You can also look to the right of this screen for links and FAQs that may be of immediate interest to you.
“Screening” is the act of running the name of the person(s) and/or entity(s) with which you are engaging in a proposed research or academic activity, procurement or vendor transaction, sub-awardee relationship or any other “transaction” involving the person or their property, against the various “U.S. Lists to Check.” Screening a person or entity prior to engaging in an activity with them prevents Johns Hopkins University from inadvertently engaging in a violation.
The U.S. Department of Treasury, Office of Foreign Assets Control (“OFAC”) enforces U.S. economic sanctions, which are laws and regulations that restrict and, in some cases, completely prohibit, U.S. persons (wherever located) from engaging in transactions or “doing business with” designated persons and entities. In particular, OFAC publishes the Specially Designated Nationals and Blocked Persons List (“SDN List”), which is a constantly updated list that is part of a program of economic and trade sanction regulations targeting foreign countries and regimes, as well as individual bad actors, such as terrorists, or international narcotics traffickers. Several other U.S. federal agencies, such as the Department of Commerce, also maintain lists of persons and entities, where certain exports or financial transactions may be prohibited or require prior authorization.
JHU takes compliance with these economic sanctions and trade requirements seriously. As a U.S. entity, JHU is obligated to avoid ‘doing business’ with those who are found on the SDN List. And, failure to comply with OFAC regulations can result in criminal and civil penalties for the University and its employees.
If you or your department has a question about screening or economic sanctions regulations, contact JHU’s Export Controls Office (“ECO”) at ECO@jhu.edu. You are also able to engage in initial screening using free online tools, such as the International Trade Administration’s Consolidated Screening List and OFAC’s Sanctions Lists.
JHU’s Export Control Office (“ECO”) develops, implements, monitors and documents practices that promote compliance with one or more bodies of U.S. export control and economic sanctions program regulations. Such practices generally involve screening subject matter and its potential end-uses, countries represented, and personnel associated with JHU’s educational, research and clinical/technical service activities. ECO assists with the procurement of licenses, or with the structuring of such activities, in order to ensure that they are authorized by U.S. law/regulation. ECO also promotes informed, collaborative compliance within the JHU community.