We use a commercial software package, Visual
ComplianceTM, to screen persons and entities against 60 lists maintained by regulatory and law enforcement agencies of the US government, governments of other countries (eg, UK, Canada, Australia, Japan), and international agencies (eg, Interpol, World Bank).
We consult the CCL and the USML to screen commodities, and Sanctions Programs and Country Information to screen countries.
Who and what should be screened?
- Visa beneficiaries (H1B and J1)
- International Visitors
- Foreign collaborators -Hosts at travel destinations; Conference organizers
- Visa beneficiaries' institutions (ie, where they trained or worked)
- Foreign vendors
- Foreign funders of research
- Foreign travel destinations
Where a commodity is being shipped; travel destination; location of a conference.
Screening the Commodities lists – technically called determining the classification of an article – is probably the most difficult part of analyzing whether a license is needed in a particular situation.
Who does the screening?
Optimally, screening should happen at the first administrative office that receives a request to use university funds for foreign travel, sponsor a foreign visitor, hire a potential H1B or J1 visa beneficiary, or ship an item to a foreign location..
Staff members in various university offices have been trained in how to conduct screen of persons and entities using VC.
Anyone can screen!!
As noted previously, the various lists maintained by government agencies are publicly available. The Consolidated Screening List allows searching of 8 lists simultaneously. It is easy to use but the results can be difficult to interpret, so feel free to contact this office for assistance.
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