The Office of Foreign Assets Control (OFAC) of the US Department of the Treasury administers economic and trade sanctions against specific countries, individuals and entities. These trade sanctions programs apply to University activities. The most comprehensive sanctions involve Cuba, Iran, North Korea, Sudan and Syria. For the most recent list of sanctions see this OFAC website: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/Programs.aspx.
What do I need to do?
Contact the Export Control Officer for guidance as soon as possible, for any of the following, involving a comprehensively sanctioned country, listed individual or entity:
- any imports/exports (examples include research samples, artwork, or any research material)
- collaboration with individuals residing in a sanctioned country
- research in
- travel to (including to attend a conference)
- transfer of funds to
OFAC sanctions change regularly. Please contact the Export Control Officer as soon as possible for the most recent guidance to avoid penalties and delays to your research.
If a license is required, it will likely take 3 months plus to obtain one.
Who this applies to
OFAC regulations apply to all United States persons. The term U.S. person means any United States citizen, legal permanent resident, or green card holder, regardless of whether they are located in the U.S. or abroad. It also includes any entity organized under the laws of the United States, or any foreign nationals who are currently located in the United States or in some cases outside the U.S.
Exempt Transactions/License Exceptions
Under OFAC sanctions, there is an exception for the export or import of information and informational materials regardless of the format or medium. This exception does not apply to export controlled technical data or to information and informational materials not fully created and in existence at the date of the transaction, or to the substantive or artistic alteration or enhancement of informational materials. See § 560.210 of the Iranian Transactions and Sanctions Regulations Exempt Transactions.
There is also an exception for peer review activities. See § 560.538 of the Iranian Transactions and Sanctions Regulations Authorized Transactions Necessary and Ordinarily Incident to Publishing.