Taking action to minimize IU'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 Unverified List (UVL) is distinguished from those lists in that it represents more of a caution sign than a hard stop. The Bureau of Industry and Security (BIS) 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. IU's Export Control and the Office of the Vice President for International Affairs (OVPIA) receive notifications from a system called Visual Compliance 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.