Prohibited Individuals and Entities

Compliance Strategies
  • Use Yale’s systems for making payments, shipping items, and transferring materials.  Yale’s systems include screening processes to prevent transactions with prohibited parties.
  • If you must make a payment overseas outside of Yale’s systems (e.g., an out-of-pocket expense which will be reimbursed later), have the transaction screened in advance.  Contact the Director, Corporate Contracts and Export Control Licensing for help.
  • Follow Yale policies and procedures related to financial transactions, shipping, materials transfers, and other international activities.   See Accounts Payable Policies and Procedures, including Policy 3401, Payment Policy, General and review Yale Business’ Express Shipping instructions.
  • Conduct appropriate due diligence when entering into any significant financial transaction, especially if the transaction will not be processed through Yale payment or shipping systems.
  • Contact the Director, Corporate Contracts and Export Control Licensing (Office of Grant and Contract Administration) early to discuss applying for a license.  The process of preparing the application is time-consuming and the wait for review and approval by the U.S. government agency can be lengthy.

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