Pol-Sanction Check Screening

policy policy sanction check screening modified Thu Mar 11 2021 11:00:29 GMT-0500 (Eastern Standard Time)

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University of Louisville

OFFICIAL
UNIVERSITY
ADMINISTRATIVE
POLICY

POLICY NAME

Sanction Check Screening

EFFECTIVE DATE

December 18, 2007

POLICY NUMBER

ICO-1.02

POLICY APPLICABILITY

This policy applies to University of Louisville employees (administrators, faculty, staff, and student employees), Vendors, and affiliated individuals.

POLICY STATEMENT

The University of Louisville (University) exercises due diligence in hiring and screening employees, Vendors, and affiliates. University employees, Vendors, and appropriate affiliated individuals must be checked against appropriate governmental exclusion, debarment, and suspension lists to ensure eligibility for hire and/or to participate in University programs.

RELATED INFORMATION

SanctionCheck.com Training Videos (requires sanctioncheck.com user log-in)

SanctionCheck.com User Support (requires sanctioncheck.com user log-in)

DEFINITIONS

Affiliated Research Personnel – any non-University employed individuals involved in University research.

Vendor – any organization or individual providing goods or services to the University, excluding refunds and reimbursements.

Contractor – any individual or other legal entity that enters into a contract/agreement for goods and services made through Contract Administration and Procurement Services equal to or exceeding $25,000.

PROCEDURES

University employees, Vendors, and appropriate affiliated individuals are checked against, but not limited to, the following federal and state exclusion, debarment, and suspension lists:

  • U.S. Department of Health and Human Services, Office of Inspector General’s (OIG) List of Excluded Individuals/Entities (LEIE)
  • General Services Administration’s (GSA) System for Award Management (SAM) Excluded Parties List System (EPLS)
  • U.S. Food and Drug Administration’s (FDA) Debarment List and Disqualified/Totally Restricted List for Clinical Investigators
  • U.S. Department of the Treasury, Office of Foreign Asset Control’s (OFAC) Specially Designated Nationals (SDN) & Blocked Persons List, Consolidated Sanctions List (Non-SDN sanctions, including Foreign Sanctions Evaders)
  • U.S. Department of Commerce (DOC), Bureau of Industry and Security’s (BIS) Denied Persons List, Entity List, and Unverified List
  • U.S. Department of State’s (DOS), Directorate of Defense Trade Control’s List of Statutorily Debarred Parties and List of Administratively Debarred Parties
  • Kentucky Cabinet for Health and Family Services, Department for Medicaid Services (DMS) List of Excluded Providers 

The sanction check screening process includes identification and verification of an individual/entity name of a prospective employee, employee, prospective Vendor, Vendor, or affiliated individual that potentially matches to a sanctioned individual/entity name identified on an applicable governmental exclusion, debarment, or suspension list and determining if the identified name is a positive match and if the individual/entity is eligible for hire and/or participation in University programs. The verification procedures, system user instructions, and associated certification forms are provided below: 

RESPONSIBILITIES

The following administrative offices and departments are responsible for sanction check screening procedures as follows:

University Integrity and Compliance Office (UICO) is responsible for administering and overseeing the University’s sanction check policy and procedures, including the following: 

  • Review and renewal of the University’s contract/agreement with the third-party Vendor (currently ComplianceLine, Inc.) for sanction check services provided, including the online searchable database system (currently SanctionCheck.com). 
  • Serve as the System Administrator for the sanction check online searchable database system (currently SanctionCheck.com) and train new users how to use the system.
  • Maintain the University’s Sanction Check policy and procedures, and serve as the subject matter expert, in conjunction with the Office of the Vice President for Strategy and General Counsel and other University compliance officials, on federal and state agency exclusion and debarment requirements. 
  • Complete annual sanction check screening of all active University employees and maintain supporting documentation. The UICO receives a list of all active University employees annually on September 1st from orionwf@louisville.edu.
  • Complete monthly sanction check screening of all active University Health Sciences Center (HSC) employees and maintain supporting documentation. The UICO receives a list of active HSC employees monthly from orionwf@louisville.edu.
  • Complete annual sanction check screening of University Procurement Card merchants with annual expenditures of $500 or greater and maintain supporting documentation. The UICO obtains a list of all merchants with annual expenditures of $500 or greater from the Card Services Department.


Human Resources Department (HR) – Responsible for ensuring a sanction check screening is completed of all new University employees for verification of employment eligibility prior to hire date. The sanction check screening is included as part of the applicant’s criminal background check.  HR is responsible for maintaining supporting documentation of sanction check screenings and reporting confirmed positive matches to the UICO for joint determination and implementation of appropriate action.

Business Operations Department – Responsible for sanction check screening of new University employees who are exempt from University’s criminal background check screening process conducted through the HR department.   Business Operations is responsible for maintaining supporting documentation of sanction check screenings and reporting confirmed positive matches to the UICO for joint determination and implementation of appropriate action.

Controller’s Office – Accounts Payable Department – Responsible for sanction check screening of all new University Vendors via SanctionCheck.com and recurring monthly screening of active Vendors with transactions. The sanction check screening procedures of Vendors is part of the University’s Vendor eligibility and approval process. Accounts Payable is responsible for maintaining supporting documentation of sanction check screenings and reporting confirmed positive matches to the UICO for joint determination and implementation of appropriate action.

Contract Administration and Procurement Services – Responsible for sanction check screening of new University Contractors and Contractor renewals via SanctionCheck.com.  The sanction check screening is done prior to contract award and is part of the contract eligibility process.  Contract Administration and Procurement Services is responsible for maintaining supporting documentation of sanction check screenings and reporting confirmed positive matches to the UICO for joint determination and implementation of appropriate action. See Purchasing Policy #13.00 – Eligibility to Participate in Governmental Programs.

Office of Research Integrity (ORI) – Responsible for sanction check screening of Affiliated Research Personnel via SanctionCheck.com to help ensure the individual’s eligibility to participate in University research programs.  ORI is responsible for maintaining supporting documentation and reporting confirmed positive matches to the UICO for joint determination and implementation of appropriate action. Contact ORI at ori@louisville.edu for Standard Operating Procedures Manual #RI-050.

Office of Sponsored Programs Administration (OSPA) – Responsible for sanction check screening of subcontractors/subrecipients prior to execution of subcontract/subaward for federal contracts or federal flow-through contracts via SanctionCheck.com. OSPA is responsible for maintaining supporting documentation and reporting confirmed positive matches to the UICO for joint determination and implementation of appropriate action.

ADMINISTRATIVE AUTHORITY

Vice President for Risk, Audit, and Compliance

RESPONSIBLE UNIVERSITY DEPARTMENT/DIVISION

University Integrity and Compliance Office
425 W. Lee Street
Louisville, KY 40208
Phone: 502.852.8305
compliance@louisville.edu

HISTORY

Revision Date(s): March 10, 2021 (minor revisions, combined policy and procedure documents); January 25, 2019 minor revisions; December 20, 2017; January 23, 2009

Reviewed Date(s): March 10, 2021; December 20, 2017; October 23, 2014

The University Policy and Procedure Library is updated regularly. In order to ensure a printed copy of this document is current, please access it online at http://louisville.edu/policies.