Entities on the Unverified List (UVL): Create or Renew Agreements: International Partnerships: 51�� Global: Indiana University

Home
International Partnerships
Create or Renew Agreements
Entities on the Unverified List (UVL)

Entities on the Unverified List (UVL)

Taking action to minimize 51��'s risks with international partnerships

U.S. Government agencies maintain restricted party lists identifying organizations and individuals with which “U.S. persons,” including Indiana University, are prohibited from doing business. Those lists include the Entity List and the Denied Persons List.

The is distinguished from those lists in that it represents more of a caution sign than a hard stop. The adds entities to the UVL 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. 51��'s and the Office of the Vice President for International Affairs (OVPIA) receive notifications from a system called when a previously screened international partner is added to the UVL.

Based on discussions with other U.S. academic institutions, most universities consider an international partner’s status on the UVL as a risk factor but not as an outright prohibition to the partnership or collaboration.

Academic Institutions on the Unverified List (as of 12/01/2020)

Anhui Institute of Metrology (China)
Hefei Institutes of Physical Science, Chinese Academy of Sciences
Guangdong University of Technology (China)
Nanching University (China)
Shanghai Institute of Applied Physics, Chinese Academy of Sciences (China)
Sun Yat-Sen University (China)

The next steps: What to expect

OVPIA currently notifies Export Control whenever an application for a new international partnership agreement or a renewal of an existing agreement is submitted. Export Control reviews all applications.

When an entity with which 51�� has existing agreements is added to the UVL, 51�� will take the following steps, as appropriate:

Upon renewal of a primary agreement or similar university-level agreement, general language will be added to the document about compliance with applicable laws, including specific reference to export control regulations.
- i.e., “The Parties acknowledge and agree that any activity under this Agreement must be organized and administered in accordance with applicable laws, including export control laws, and the relevant policies and procedures of each Party.”
Upon renewal of a sub-agreement or unit-level agreement, or the signing of a new one, that presents export control concerns, specific language will be added to the document about compliance with export control regulations, including required completion of a UVL Statement for all relevant exports.
OVPIA will review all current sub-agreements with the international partner, notify all relevant units about the partner’s placement on the UVL, and work with those units to identify the ongoing activities and programs associated with the partner.
OVPIA will communicate to Export Control about the ongoing activities and programs associated with the partner and direct the relevant units to contact Export Control before transferring anything to the partner.
Export Control will develop specific guidance for each unit, as necessary, on how to comply with Export Control requirements when shipping items or transferring other data to the partner.

When an entity with which 51�� has existing agreements is removed from the UVL, 51�� will take the following actions:

Export Control will notify OVPIA of the removal.
OVPIA will notify all relevant units of the removal.
Upon renewal of any sub-agreements or unit-level agreements, remove any specific language pertaining to requirements or restrictions related to placement on the UVL.

When 51�� is contemplating an agreement with a new entity on the UVL, 51�� will take the following action:

OVPIA, Export Control, the General Counsel’s Office, and the relevant unit will consult about the agreement and the activities being proposed and determine whether it is reasonable for 51�� to go forward with the proposed arrangement.

51������