University activities that involve any type of transaction (e.g., transfer information, data or technology; shipping materials; payment of funds; hosting a visitor; travel to an embargoed country, etc.) with a Non-U.S. person or entity from an embargoed or sanctioned country may be subject to export controls and in some cases strictly prohibited by the U.S. government.
For example, providing professional consulting services overseas, especially to embargoed or sanctioned countries (e.g., Cuba, Iran, Syria, Sudan and North Korea) is in most cases strictly prohibited. A general or specific export license is required by OFAC for all research and educational activities to an embargoed or sanctioned country. OFAC embargoed country list included Balkans, Belarus, Myanmar (Burma), Central Africa Republic, Cuba, Democratic Republic of the Congo, Cote D’Ivoire (formerly Ivory Coast), Cuba, Iran, Iraq, Lebanon, North Korea, Liberia, Libya, Somalia, Sudan, Syria, Ukraine/Russia, Venezuela, Yemen and Zimbabwe. The List-Based sanction program include:
- Anti-Terrorism
- Counter Narcotics Trafficking
- Non-proliferation
- Diamond Trading
In addition to the OFAC embargoed countries, EAR and ITAR proscribed additional non-embargoed countries that prohibited from receiving “controlled” technology, data, or items (technology, data, or items are considered to be “controlled” if found on the EAR Commerce Control List or the ITAR Munitions List). This includes the transfer of “controlled” technology, data, or items to foreign nationals within or outside the United States.
EAR Part 746 Embargoes – Comprehensive controls
- Cuba [also Part 740 Country Group E:2, Unilateral Embargo]
- Iran
- Syria
EAR Part 746 Embargoes – Sanctions on selected categories of items to specific destinations.
- Central African Republic
- Cote d’Ivoire
- Democratic Republic of Congo
- Eritrea
- Iraq
- Lebanon
- Liberia
- Libya
- Korea, Democratic People’s Republic of [North Korea]
- Somalia
- Sudan
- Crimea Region of Ukraine
- Russian Industry Sector Sanctions
Department of State Arms Embargoes (ITAR 126.1 Prohibited Export Destinations)
- Afghanistan
- Belarus
- Burma
- Central African Republic
- China [PRC]
- Democratic Republic of the Congo
- Cote d’Ivoire [Ivory Coast]
- Cuba
- Cyprus
- Eritrea
- Haiti
- Iran
- Iraq
- Lebanon
- Liberia
- Libya
- Korea, Democratic People’s Republic of [North Korea]
- Somalia
- Sri Lanka
- Sudan (E.O. signed Jan 13, 2017, provides for the revocation of the sanctions provisions)
- Syria
- Venezuela
- Vietnam
- Zimbabwe
The International Traffic in Arms Regulations (ITAR) prohibits exports and sales to certain countries (22CFR126.1). It is the policy of the United States to deny licenses and other approvals for exports and imports of defense articles and defense services, destined for or originating in certain countries.
Some of the sanctions are monetary in nature, and other sanctions may either prohibit shipping or require a license to ship. For example, the shipping of cotton seed to Iran requires a license or permission from OFAC. Please note: the item does not have to be military in nature to require a license. Keep in mind that foreign countries also have their own import regulations that must be followed.
If your transaction/export involves an embargoed or sanctioned country, please contact the Office of Research Integrity prior to proceeding even if the transaction includes the release of public domain or educational course information.
