Ethics, Compliance and Audit Services
International Collaborations and Economic and Trade Sanctions (OFAC)
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, Syria and specific regions of Ukraine (Crimea, Donetsk and Luhansk). For the most recent list of sanctions see this OFAC website: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/Programs.aspx.
In general, collaborations between university personnel and scholars at foreign institutions or organizations do not require export licenses unless they involve export controlled or restricted research or services, restricted entities or sanctioned countries. Before engaging in an international collaboration, the university needs to determine if export licenses are required and to verify that the foreign individual and/or organization are not blocked or sanctioned.
What do I need to do?
Contact your location Export Control Officer 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 your location Export Control Officer as soon as possible for the most recent guidance to avoid penalties and delays to your research.
Licensing Timelines
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.Example Exempt Transactions/License Exceptions
Your location Export Control Officer can work with you to determine if an exemption or exception applies to your planned activities or if a general license is available. 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. For example see § 560.210 of the Iranian Transactions and Sanctions Regulations Exempt Transactions. There is also an exception available under OFAC sanctions related to peer review activities. For example, see § 560.538 of the Iranian Transactions and Sanctions Regulations Authorized Transactions Necessary and Ordinarily Incident to Publishing.
Record Keeping
Record keeping is required under OFAC sanctions regulations. See “Export Control” on the UC Records Retention Schedule.
Compliance Alerts
Federal laws may regulate research/telework from certain countries (pdf)
Updated Sanctions on Russia, Belarus and Specific Regions of Ukraine (pdf)