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Payments to Non-U.S. Entities

Payments for equipment, supplies, sub-awards and contracts need to be screened when going to persons, institutions, businesses and organziations external to the university and outside the United States. This prevents prohibited parties from receiving money and helps protect against financial gain by an embargoed country.

Although accounts payable staffer generally screens financial institutions, occasionally they will contact you or the export control office with questions before paying vendors, contractors or suppliers. In order to minimize these situations, we encourage you to:

  1. Use suppliers that have incorporated in the U.S. 
  2. Purchase through the U.S. branch of the company or institution.
    • e.g., purchase through Oxford University Press USA rather than the parent office in the United Kingdom.
  3. If you have questions or concerns, do a quick Internet search on your prospective company combined with the words “export control.” This should help turn up any news stories about the company/person, including possible violations. 
    • If there are violations, the U.S. Department of Commerce likely has restricted them and we recommend you find another supplier.
  4. When you are traveling and not able to use the university purchasing /payment system, pay with a credit card. It creates a better payment trail and provides third party protection because the credit card company and its financial institution will handle the payments to a foreign entity.