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 University Policies, Procedures, Forms & Guides, 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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