Office of Foreign Assets Control (OFAC)
The Department of the Treasury, Office of Foreign Assets Control (OFAC), enforces trade embargoes, sanctions, and financial transaction prohibitions against targeted foreign governments, entities, individuals and certain practices (such as proliferation of weapons of mass destruction and diamond trading).
Prohibited OFAC Activities that Require Approval by the Office of Research & Commercialization and a License from the U.S. Department of the Treasury
- Furnishing financial assistance, materials or services to a sanctioned country, or entity,
- Travel to an embargoed country (Cuba, Iran, North Korea, Sudan, and Syria),
- Research, field-work, or instruction in a sanctioned country,
- Importing merchandise from a sanctioned country,
- Collaborating, presenting or training a blocked individual, organization or entity.
Impacts of Prohibitions to Universities
- Limitation on research collaboration. Some collaborations between university personnel and scholars at foreign institutions or organizations in a sanctioned country may qualify for a General License or License exception,
- Verification that the foreign individuals and/or organizations are not blocked or sanctioned entities,
- Prohibition on collaborating with scholars or peers in a sanctioned country if the research involves export controlled items or data.
Sanctioned and Embargoed Countries
|Comprehensive||Limited||Regime / List Based|
|Iran||Ivory Coast (Cote d’Ivoire)||Belarus|
|Sudan||North Korea||Congo (Democratic Republic)|
Types of Sanctions
Osama Bin Laden:a
"Specially Designated National"
Specially Designated Nationals
and Blocked Persons
Comprehensive Sanctions: Generally prohibits all direct or indirect imports/exports, trade brokering, financing or facilitating against most goods, technology and services. Transactions will require a specific license or exemption from OFAC before any transaction can take place.
Limited Sanctions: Block specific practices, such as diamond trading. Most research and business activities may be conducted without an OFAC special license, so long as specific criteria are met as outlined in the regulations for a General License.
Regime or List Based Sanctions: Blocks specific property of targeted foreign governments, regimes, supporters and persons that are not necessarily country-specific, but which may be owned, controlled by, or acting for or on behalf of, targeted countries or entities as a front organization. Collectively, such targeted individuals and entities are called "Specially Designated Nationals.”
General Licenses and License Exemptions Applicable to Universities
Information and Informational Materials (License Exemption): Allows for importation and exportation of information or informational materials to those already in the public domain, and does not authorize financial transactions or services of value.
Humanitarian Activities (License Exemption): Allows for transactions sponsored by any United States 501(c )(3) qualified non-governmental organization and are country-specific and narrowly tailored. The exemption is not available for all sanctioned countries.
Authorized transactions necessary and ordinarily incident to publishing (General License): Allows for activities in support of publishing (academic peer review) and/or marketing of informational materials with:
There may be other license exemptions available on a country-by-country basis.