Overview
U.S. government agencies maintain lists of individuals, institutions, companies, and other organizations that have been identified as presenting national security, foreign policy, export control, sanctions, or other risks. Increasingly, federal research sponsors are using these lists to restrict or prohibit certain research relationships.
Researchers should understand that restrictions may apply not only to funded transactions, but also to research collaborations, appointments, affiliations, and other forms of support involving a listed party.
What are Restricted and Proscribed Parties?
Federal agencies and research sponsors use different terms, including restricted parties, proscribed parties, and high-risk entities, to identify individuals and organizations that are subject to particular restrictions or heightened scrutiny.
The consequences of appearing on a federal list vary. Depending on the particular list and activity:
- Certain transactions may be prohibited.
- An export, transfer, or other activity may require prior U.S. government authorization.
- Federal funds may not be used to support a collaboration.
- A federal research sponsor may prohibit investigators from collaborating with, holding an appointment or position with, or receiving research support from a listed party.
- Additional institutional or sponsor review may be required.
Appearance on a federal list does not necessarily mean that every interaction with an individual or entity is prohibited. The applicable restrictions depend on the particular list, activity, funding source, sponsor requirements, and other circumstances.
If a screening identifies a potential match, or you are considering an engagement with a listed party, you must contact UCSF Export Control and Research Security before proceeding. Learn how to perform a Restricted Party Screening.
Federal Research Security Restrictions are Expanding
Federal research sponsors are increasingly incorporating restricted-party lists into their research security requirements.
In July 2026, the National Science Foundation (NSF) announced a forthcoming policy that will prohibit certain relationships with entities appearing on specified U.S. government restricted-party lists. NSF has stated that, for NSF-funded projects involving these entities, research security risk mitigation is not sufficient.
Once the policy becomes effective, NSF intends to:
- Prohibit NSF funds from being used to conduct research in collaboration with a restricted entity or its employees.
- Prohibit senior/key personnel from collaborating with a restricted entity or its employees on research funded by their NSF award.
- Prohibit senior/key personnel from holding an appointment or position with a restricted entity for the duration of the NSF award.
- Prohibit senior/key personnel from receiving research support from a restricted entity for the duration of the NSF award.
- Require organizations and senior/key personnel to certify compliance at proposal submission.
- Require recipient institutions to identify and address prohibited activities before NSF funds are expended.
NSF anticipates implementing the prohibition in Fiscal Year 2027 and has stated that its approach is intended to align with the Department of War’s (DoW) approach to research security restrictions.
Read the NSF Dear Colleague Letter: Prohibition on Collaborations with Restricted Entities
Other federal sponsors may impose different or additional restrictions.
Researchers should review the requirements applicable to each federal sponsor.
What Types of Research Relationships may be Affected?
Depending on the applicable federal requirement, activities involving a restricted or proscribed party may include:
- Funded or unfunded research collaborations
- Publication and co-authorship relationships with a restricted or proscribed party, or its personnel, when they reflect an ongoing or substantive research collaboration
- Subawards, subcontracts, consulting arrangements, or other sponsored research relationships
- Academic, research, visiting, honorary, or other appointments or affiliations
- Research support, whether monetary or in-kind
- Access to laboratories, equipment, facilities, personnel, or other research resources
- Exchange or transfer of research data, software, technology, biological materials, or other research materials
- Consulting or advisory relationships related to research
- Foreign-sponsored travel or other financial support associated with a research relationship
The applicable requirements depend on the nature of the activity, the parties involved, the funding source, and the terms and conditions of the relevant award.
Contact UCSF Export Control and Research Security before proceeding if:
- A Restricted Party Screening identifies a potential match or other concern.
- An individual or institution involved in your research appears on a federal restricted or proscribed-party list.
- A federal sponsor identifies or questions a collaborator, affiliation, appointment, or other relationship.
- You are considering accepting an appointment, research support, or other resources from an entity that may be restricted.
- You are uncertain whether a proposed or existing relationship is permissible.
Do not independently determine that an existing relationship must be terminated solely because an individual or organization appears on a federal list. Contact Research Security and Export Control so that the applicable restrictions and sponsor requirements can be evaluated.
Resources and Questions
- Your Role in Keeping UCSF Research Secure
- International Collaborations
- Performing Restricted Party Screenings
- Disclosing Foreign Collaborations and Support
- Foreign Appointments and Foreign Support
- Research Security Requirements by Federal Sponsor
- UCSF's Research Security Program
If you have questions about a proposed or existing research relationship involving a restricted or proscribed party, contact UCSF Export Control and Research Security before proceeding.