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Visual Compliance
Mason is a part of a statewide license that allows all major universities in the commonwealth to use a third-party tool for restricted party screening called Visual Compliance. Visual Compliance is also widely used by universities across the U.S.
Restricted party screening is a key aspect of Mason’s fundamental due diligence. As such, ORIA has trained staff across the university (see table below) to use Visual Compliance to screen individuals or entities against all of the various U.S. government lists, which are updated frequently. Visual Compliance will also rescreen on a daily basis to alert the Export Office if there is a match to a previously screened individual or entity.
Restricted Party Screening
The U.S. government maintains various government lists, which are publicly available, such as the Specially Designated Nationals (SDN) list, the Entity List, Unverified List, and many others, which are updated on a regular basis. U.S. persons may have restrictions on their interactions with individuals or entities on these lists. These restrictions include providing “benefits” or services, exchanging export-controlled technology or information, and so forth (the restrictions will vary depending on the specific list).
As a U.S. university, Mason is required to ensure that it is not interacting with any prohibited parties on those lists and conduct an evaluation if and when an institution or individual is on a list. Recent guidance from the U.S. government on export control considerations for the academic community notes that “incorrect screening procedures” have resulted in universities being subject to export violations due to transactions with persons named on the Entity List, further demonstrating the importance of robust and consistent screening at all stages of the transaction, shipment, or contemplated collaboration.
Screening Tips
- Screen both the names of individuals and their associated organizations separately (If screened together, we may miss a match)
- Screen everything – including organizations like companies and universities – in the NAME field (not the Company field)
- Screen the entire legal name of a company, including “University”, “Inc.” and “Corp.”
- Capitalization is not relevant
- Do not add spaces between the letters of an acronym
- Do not use accented letters or special characters
- Do not copy/paste from a pdf document
- For hyphenated names, include both last names with the hyphen
- Include Name and Country only; use country of residence
- Comment is necessary for auditing purposes and daily screening
- If you make a mistake or have a typo, email [email protected] so we can delete the screening
Common Screening Errors
- Screening under the “Company” field
- Screening an individual under “Name” and including their affiliated institution under “Company”
- Not including the full name of the individual or organization/institution
- Not adding an identifying comment
If you make any errors while screening or conduct any test screening, please reach out to [email protected] so that we can remove those records from Dynamic Screening.
Screeners
Who is responsible for screening?
| Entity/Individual | Responsible Screeners |
| Affiliates | Department |
| Guest Speakers (International Only) | Department |
| Consulting Contracts (eVA) | OSP |
| P-Card purchases | Department |
| eVA purchases | Purchasing |
| Grant Subcontracts | OSP |
| Employees | HR |
| Membership payments for Faculty members (International Organizations Only) | Department |
| International Conferences that faculty attend (Only non-Government) | Department |
Who should I contact to conduct screening for me?
Please see the table below.
| First Name | College | Notes | |
| Vivian Carrera | [email protected] | CCB | |
| Beth Cecka | [email protected] | CCB | |
| Gabby Griffis | [email protected] | CCB | |
| Tara Hammond | [email protected] | CCB | |
| Giovanna Hernandez | [email protected] | CCB | |
| Margaret Kebe | [email protected] | CCB | |
| Yashika Wright | [email protected] | CCB | |
| Sarah Alharshan | [email protected] | CEC | |
| Elizabeth Dean | [email protected] | CEC | |
| Amal Nadel | [email protected] | CEC | |
| Michele Pieper | [email protected] | CEC | Department of Computer Science |
| Justin Thorpe | [email protected] | CEC | C5I |
| Taylor Kenestrick | [email protected] | CHHS | Department of Economics |
| Maria Carabelli | [email protected] | CHSS | Department of Communication |
| Barbara Gomperts | [email protected] | CHSS | English Department |
| Farhana Islam | [email protected] | CHSS | Department of Sociology and Anthropology |
| Hyonson Yi | [email protected] | CHSS | |
| Alison Langford | [email protected] | CHSS | |
| Krystalyn Morton | [email protected] | CHSS | |
| Jutonya Myers | [email protected] | CHSS | |
| Kenneth Santos | [email protected] | CHSS | |
| Susan Woods | [email protected] | CHSS | |
| Katharine Rupp | [email protected] | CHSS | Center for Social Science Research |
| Katherine Foarde | [email protected] | CHSS | Department of Sociology and Anthropology |
| Rachida Abuzaid | [email protected] | COS | |
| Natasha Boddie | [email protected] | COS | Center for Applied Proteomics & Molecular Medicine |
| John Crocker | [email protected] | COS | |
| Maria D’souza | [email protected] | COS | |
| Virginia Espina | [email protected] | COS | Center for Applied Proteomics & Molecular Medicine |
| Megan Grant | [email protected] | COS | CIDR-Biomedical Research Lap |
| Hillary Hamm | [email protected] | COS | |
| Tammie Howell | [email protected] | COS | |
| Natalie Lapidot-Croitoru | [email protected] | COS | |
| Monique Sweeney | [email protected] | COS | |
| Cheriden Tellis | [email protected] | COS | |
| Joanne Zimmerman (Anderson) | [email protected] | COS | |
| Claudia Rich | [email protected] | COS | |
| Crystal Broomall | [email protected] | CVPA | |
| Brian Benison | [email protected] | LAW |
Frequently Asked Questions
Who should I screen?
Please note both name and affiliated institution or company must be screened for each of these:
- All international parties must be screened, including:
- International collaborators
- International guest speakers
- Visiting foreign delegations
- Visiting Scholars (H-1B and J-1 applicants)
- Affiliates
- Unfamiliar or international vendors
- Vendors if a purchase meets the following criteria:
- Equipment that is over $2,000, excluding basic office equipment such as computers, laptops, printers
- If the manufacturer is located outside the U.S.
- If the purchasing paperwork includes export control language
- If the person who will use the equipment intends to hand carry or ship the equipment to another country
When is the appropriate time to screen?
Please screen as soon as there is serious interest, so we can ensure to review any risks ahead of time.
Note: All university personnel, when completing a Chrome River preapproval request for international travel, will be asked to certify that any foreign contacts (institutions or individuals) for planned meetings, research or collaboration have been screened in Visual Compliance.
What is a “foreign contact” for screening purposes?
“Foreign contact” refers to individuals or institutions who you expect to conduct research and/or collaborate with related to your role at Mason who are located outside of the U.S. A foreign contact does not include every single conference or meeting attendee, chance/spontaneous encounters you may have, hotel employees, etc.
What about new contacts I make while abroad?
If you expect that a new foreign contact may result in planned research or future research collaborations, or continued meetings related to your role at Mason, we recommend Visual Compliance screening. You can have screening conducted by reaching out to your college’s screener (see table under Screeners) or [email protected]. We do not conduct screening for any personal contacts you make, or for every single individual you encounter while abroad.
Do I need to verify citizenship for any foreign contacts?
No. Visual Compliance screening is not related to the citizenship or the nationality of any individual screened. The basic information needed to screen in Visual Compliance is a full name and associated institution or company.
What if I receive a match?
If you receive a match, please email the results or send it via Visual Compliance to [email protected] and we will evaluate and determine next steps. You do not need to contact the individual.
Are screeners responsible for communicating to the individual being screened if they show up on the list?
If there is a match, screeners are not responsible for communicating the restriction directly with the affiliate. If you get a potential match that you would like us to review, please contact [email protected].
Is this a background check?
No, this is not a background check, however it is a requirement for due diligence. Screening in Visual Compliance is simply entering publicly available information (such as a person or entity’s name and country), then screening them against publicly maintained U.S. government lists. It is the equivalent of a Google search, but with hundreds of saved hours, and with all of the public lists consolidated into one place. Therefore, screeners do not need to disclose to the individual that they will be screening them.
Help! How can I convey messaging around Visual Compliance needs to our faculty/staff?
Please direct them to both this website and to [email protected] for any further questions.
How can I become a screener?
Please reach out to [email protected].
I have more questions, and I’m not sure if I should screen.
Please contact [email protected].