Responsible Administrator(s):
Responsible Office(s):
Originally Issued: July 2024

Statement of Purpose

The U.S. Government periodically publishes laws, regulations, executive orders, or directives that identify entities, companies or persons that are prohibited or restricted from engaging in specific transactions or activities that may apply to institutions of higher education. Activities such as international travel, research collaboration, providing or receiving services, and/or hosting visitors from entities will require a review by the Export Control Officer prior to engaging in any activities with them. 

The Bureau of Industry and Security (BIS) maintains three lists of parties of concern. In the event an individual or entity is listed, an exporter cannot continue the proposed action without further requirements or authorization. In many cases, the BIS license policy is to deny such requests. 

  • Denied Persons List – A list of individuals and entities that have been denied export privileges. Any dealings with a party on this list that would violate the terms of its denial are prohibited. 
  • Entity List – Identifies foreign parties that are prohibited from receiving some or all items subject to the EAR unless the exporter secures a license from BIS. 
  • Unverified List – A list of parties whose bona fides BIS has been unable to verify. No license exceptions may be used for exports to unverified parties. BIS adds entities to the Unverified List when BIS is unable to verify the entity’s bona fides—the entity’s legitimacy and reliability regarding end use or end user(s) of items subject to the Export Administration Regulations (EAR). Typically, this happens when an end-user check could not be completed satisfactorily for reasons outside the U.S. Government’s control.

Entities Affected by this Policy

All UNLV units are affected by this policy.

Who Should Read this Policy

All UNLV employees must read and understand this policy.

Policy

The U.S. Government has a policy of denial related to export authorizations related to a Denied Party. Due to national security concerns, UNLV does not permit the export and will not seek export approval from the U.S. Government to engage with a Denied Party or an entity that is determined by the Office of Research Integrity to be a threat to U.S. national security interests.

For parties found on the Unverified List, additional information will be requested by the Export Control Officer for a thorough risk-based assessment regarding the activities being proposed and determine whether it is reasonable for UNLV to move forward with this party or not.

Related Information

Links

Contacts

Definitions

BIS

Bureau of Industry and Security

EAR

Export Administration Regulations 

Export

An export is any oral, written, electronic, or visual disclosure, shipment, transfer, or transmission of commodities, technology, information, technical data, assistance, or software codes to anyone outside the US, including a US citizen.

Deemed Export

The release of “technology” or “software” to a foreign national in the United States is "deemed" to be an export, even though the release took place within the United States. In other words, an export of controlled “technology” or “software” can occur even if nothing ever leaves the research lab; the release can occur through, but is not limited to, a demonstration, oral briefing or provision of documents, for instance. 

Foreign National

The term "foreign national" refers to everyone other than a U.S. citizen, a permanent resident alien, and certain "protected individuals" (refugees and those with asylum); it includes any company not incorporated in the United States.