The U.S. government maintains and updates a group of lists that identify individuals and organizations that have engaged in, or are believed to support, certain activities of concern (see, e.g., , , and ). As a general rule, university employees should not engage with any person or organization on these lists without first seeking authorization from the Office of Export Controls (OEC). This would including research collaborations, material transfer agreements, external sales or shipping, foreign teaching and speaking arrangements and other transactions. OEC will assist in your efforts to analyze foreign organizations, and will provide compliance advice as appropriate, including seeking a federal license.
Compliance requires dilligence: As these lists are published and available to the foreign entities identified, the most nefarious and strategic have developed a practice of using associated business aliases to evade detection and prohibition. Although the U.S. government amends these lists to adapt to the emergence of new names, sub-units, etc., it does so with a delay. If you encounter circumstances that lead you to believe you are working with a person or organization that is acting on behalf of a foreign entity, you have a duty to inquire and conduct dilligence as to who that foreign entity might be.