U.S. Government agencies maintain lists of individuals and entities barred or restricted from entering into certain types of transactions with U.S. persons. Those lists include not only specially designated nationals but also individuals, foreign universities, and businesses that have been debarred by the Department of State or restricted by the Department of Commerce because of previous violation of the regulations. Collaborating with an individual who is from a restricted entity – particularly if located in a “foreign country of concern” (FCOC) – is extremely high risk. FCOCs are currently defined as China, Russia, North Korea, and Iran per section 10612 of the CHIPS Act of 2022.
Please contact the USC Office of Culture, Ethics and Compliance before engaging in any activity involving the sanctioned countries, entities, or individuals. If you are unsure of the status of an entity or individual, please reach out to OCEC prior to any engagement.
Check a University/Party Status
OCEC maintains a screening tool allowing for prompt identification of any sanctions or export controls that may apply to a given entity or individual. Please reach out to OCEC with any questions about whether a transaction with a particular entity or individual may be subject to restrictions.
What USC Screens:
Below is a list of categories of entities that USC screens or recommends should be screened prior to formal engagement or executed agreement with such a party:
- Industry research sponsors (domestic and international)
- Parties to inter-institutional MOU and MOA joint venture and affiliation agreements, including (but not limited to) scientific exchange programs, research collaboration, and academic exchange agreements
- Vendors (domestic and international)
- Non-Disclosure Agreement (NDA) and Material Transfer (MTA) partners
- Recipients/consignees of international shipments
- J-1 Visa Visitor Exchange candidates
- International donors of financial gifts
Screening is also advisable for:
- Visiting international delegations to the campus
- Foreign Gifts
- Subcontractors (domestic and international)
Please reach out to OCEC for guidance as to whether screening is necessary in any of these circumstances.
If you have questions or need assistance determining who should be screened and/or when to perform screening, please contact the Assistant Director of Export Controls. For additional information, please see the Department of Commerce Bureau of Industry and Security (BIS) resource Export Compliance Resources for Academic Institutions.
Restricted Party Screening – Quick FAQs
Click on each question below to expand and learn more.
What are key restricted lists to be aware of?
OFAC SDN List: Contains blocked individuals, entities, vessels, and aircraft. No interaction is allowed.
Department of Defense (DoD) 1286 List: Lists foreign institutions involved in problematic activities per the National Defense Authorization Act (NDAA). Refer to the current DoD Matrix.
BIS Entity List: Includes foreign persons/entities requiring special licenses for exports. Often, license requests are denied.
Australian Unitracker: A research-based list (not an official denied list) that sometimes overlaps with U.S. government lists.
How do I request a restricted party screening?
Contact Emily Pender (epender@usc.edu) at Export Control Compliance for screenings related to collaborators, appointments, co-authors, or conference organizers.
What if I’m associated with or traveling to a restricted party?
Contact OCEC for guidance. Activities like presenting already-published work may be allowed in limited cases, but collaborations with restricted entities—especially in countries like China, Iran, North Korea, and Russia—are typically prohibited.
Can I collaborate with someone from a restricted entity?
Usually not without a federal license, which is often denied. Sharing materials or data is prohibited. Collaborating with these entities can jeopardize your current or future funding and will likely require a mitigation plan.
What if I’m already mid-collaboration with a restricted party?
Immediately contact OCEC. Do not attempt to hide the relationship (e.g., removing names from publications). Export laws may apply, and there are serious research integrity concerns.
Can I give feedback on a paper from a restricted entity?
It depends. Consider:
• Benefit to you/USC
• Any overlap with federal funding
• Whether you’ll be listed as co-author
Consult with OCEC for a risk assessment.
Can I accept travel reimbursement or funding from a restricted party?
Generally, no. This may violate federal law and harm your risk profile. You cannot pay or accept funds from restricted parties without a license.
How do agencies assess a researcher’s risk profile?
They use risk matrices, like the DoD and Army Risk Matrices. These assess collaborations, affiliations, and funding sources—especially from restricted parties.
What does being on a denied list mean?
• Requires a license to share anything—usually denied.
• Visitors with valid visas may work on fundamental research, but cannot share data with their home (denied) institutions.
• Collaborating with such individuals may disqualify you from federal funding and is viewed as high-risk by agencies.
CSL Search Engine
The CSL Search Engine is a tool of the International Trade Administration and works with the CSL API to allow users to type in a name, country, or source agency in the search. (Best viewed in Chrome and Firefox)
The CSL search engine has “Fuzzy Name Search” capabilities, allowing a search without knowing the exact spelling of an entity’s name. In Fuzzy Name mode, the CSL returns a “score” for results that exactly or nearly match the searched name. This is particularly helpful when searching on CSL for names that have been translated into English from non-Latin alphabet languages.
The CSL Search Engine can be a helpful tool for an initial assessment; however, you must contact the USC Office of Culture, Ethics and Compliance before engaging in any activity involving sanctioned countries, entities, or individuals. If you are unsure of the status of an entity or individual, please reach out to OCEC prior to any engagement.
DoD 1286 List
As mentioned above, the 1286 List includes foreign institutions that have been confirmed as engaging in problematic activity as described in Section 1286(c)(8)(A) of the NDAA for FY 2019. The FY23 list made publicly available by the DoD is listed below. To search the webpage table for an institution or entity, use Ctrl + F on a PC or Command + F on a Mac and type in the institution name. Please note that this list may not be comprehensive, and if you do not see an institution listed below, you should still contact the Office of Culture, Ethics and Compliance to check.
FY23 Lists Published in Response to Section 1286 of the National Defense Authorization Act for Fiscal Year 2019 (Public Law 115-232), as amended.
Table 1: List of Institutions in the People’s Republic of China, Russian Federation, and Other Countries with Specified Characteristics
| Academy of Military Medical Sciences (AMMS) |
| Academy of Military Medical Sciences, Field Blood Transfusion Institution |
| Academy of Military Medical Sciences, Institute of Basic Medicine |
| Academy of Military Medical Sciences, Institute of Bioengineering |
| Academy of Military Medical Sciences, Institute of Disease Control and Prevention a.k.a. |
| Academy of Military Medical Sciences, Institute of Health Service and Medical Information |
| Academy of Military Medical Sciences, Institute of Hygiene and Environmental Medicine |
| Academy of Military Medical Sciences, Institute of Medical Equipment |
| Academy of Military Medical Sciences, Institute of Microbiology and Epidemiology a.k.a. |
| Academy of Military Medical Sciences, Institute of Radiation and Radiation Medicine a.k.a. |
| Academy of Military Medical Sciences, Institute of Toxicology and Pharmacology a.k.a. |
| Academy of Military Medical Sciences, Military Veterinary Research Institute |
| Air Force Aviation University |
| Air Force Command College |
| Air Force Communication NCO Academy |
| Air Force Early Warning Academy |
| Air Force Engineering University |
| Air Force Harbin Flight Academy |
| Air Force Logistics College |
| Air Force Medical University |
| Air Force Shijianzhuang Flight Academy |
| Air Force Xi’an Flight Academy |
| Army Academy of Armored Forces |
| Army Academy of Artillery and Air Defense |
| Army Academy of Border and Coastal Defense |
| Army Aviation Academy |
| Army Command College |
| Army Engineering University |
| Army Infantry College |
| Army Institute of NBC Defence |
| Army Logistic University |
| Army Medical University |
| Army Military Transportation University |
| Army Special Operations Academy |
| ATR Defense S&T Key Laboratory of Intelligent Information Processing at Shenzhen University |
| Beijing Aeronautical Manufacturing Technology Research Institute (BAMTRI) a.k.a. |
| Beijing Computational Science Research Center (BCSRC) a.k.a. |
| Beijing Institute of Technology |
| Beijing University of Aeronautics and Astronautics (BUAA) a.k.a. |
| Beijing University of Posts and Telecommunications (BUPT) |
| Center for High Pressure Science and Technology Advanced Research (HPSTAR) a.k.a. |
| Chinese Academy of Engineering Physics (CAEP) a.k.a. |
| Chinese Academy of Sciences – Institute of Computing Technology |
| Chinese Academy of Sciences – Shenyang Institute of Automation |
| Dalian Naval Academy |
| Defense S&T Key Laboratory of Antennas and Microwave Technology at Xidian University |
| Defense S&T Key Laboratory of Electronic Measurement Technology at North University of China |
| Defense S&T Key Laboratory of High-Power Semiconductor Lasers at Changchun University of Science and Technology |
| Defense S&T Key Laboratory of Lightweight, High-strength Structural Materials at Central South University |
| Defense S&T Key Laboratory of Multi-spectral Information Processing Technology at Huazhong University of S&T |
| Defense S&T Key Laboratory of Radar Signal Processing at Xidian University |
| Federal Autonomous Institution Central Institute of Engine-Building N.A. P.I. Baranov |
| Federal Research Center Boreskov Institute of Catalysis |
| Federal State Budgetary Institution of Science P.I.K.A. Valiev RAS of the Ministry of Science and Higher Education of Russia a.k.a. |
| Federal State Budgetary Scientific Institution Research and Production Complex Technology Center |
| Federal State Institution Federal Scientific Center Scientific Research Institute for System Analysis of the Russian Academy of Sciences |
| Federal State Unitary Enterprise All-Russian Research Institute of Physical, Technical and Radio Engineering Measurements |
| Federal State Unitary Enterprise Central Scientific Research Institute of Chemistry and Mechanics |
| Harbin Engineering University |
| Harbin Institute of Technology |
| Hefei National Laboratory for Physical Sciences at the Microscale |
| Information Engineering University |
| Institute of High Energy Physics (IHEP) a.k.a. |
| Institute of Physics Named After P.N. Lebedev of the Russian Academy of Sciences |
| Institute of Solid-State Physics of the Russian Academy of Sciences (ISSP) a.k.a. |
| Keldysh Institute of Applied Mathematics of the Russian Academy of Sciences |
| Key Laboratory of Information Systems Engineering |
| Luoyang Institute of Science and Technology |
| Mabna Institute |
| Moscow Aviation Institute |
| Moscow Institute of Physics and Technology (MIPT) a.k.a. |
| Moscow Order of the Red Banner of Labor Research Radio Engineering Institute JSC a.k.a. |
| Nanjing Institute of Astronomical Optics and Technology |
| Nanjing University of Aeronautics and Astronautics |
| Nanjing University of Science and Technology |
| National Defense University |
| National University of Defense Technology (NUDT) a.k.a. |
| Naval Aviation University |
| Naval Command College |
| Naval Engineering University |
| Naval Medical University |
| Naval NCO School |
| Naval Service Academy |
| Navy Submarine Academy |
| Northwestern Polytechnical University a.k.a. |
| Ocean University of China |
| Rocket Force Command College |
| Rocket Force Engineering University |
| Rocket Force NCO School |
| Rzhanov Institute of Semiconductor Physics, Siberian Branch of Russian Academy of Sciences a.k.a. |
| Siberian Scientific-Research Institute of Aviation N.A. S.A. Chaplygin |
| Sichuan University |
| Skolkovo Institute of Science and Technology |
| Space Engineering University |
| Sun Yat-Sen University |
| Tactical Missile Corporation, Concern “MPO—Gidropribor” a.k.a. |
| Tactical Missile Corporation, Joint Stock Company GosNIIMash a.k.a. |
| Tianjin University |
| University of Electronic Science and Technology of China |
Table 2: Foreign Talent Programs that Pose a Threat to National Security Interests of the United States
| Changjiang Scholar Distinguished Professorship |
| Hundred Talents Plan |
| Pearl River Talent Program |
| Project 5-100 |
| River Talents Plan |
| Thousand Talents Plan |
| Any program that meets one of the criteria contained in section 10638(4)(A) and either sections 10638(4)(B)(i) or (ii) of the Creating Helpful Incentives to Produce Semiconductors and Science Act of 2022 |