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 activities require a license
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,
Research, field-work, or instruction in a sanctioned country,
Collaborating, presenting or training a blocked individual, organization or entity.
Travel to an embargoed country (Cuba, Iran, North Korea, Sudan, and Syria),
Importing merchandise from a sanctioned country,
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.
University personnel are allowed to participate in normal academic peer-review of the publishing process with certain sanctioned countries using a General License (see below).
Sanctioned and Embargoed Countries
Comprehensive
Cuba
Iran
Sudan
Limited
Burma/Myanmar
Ivory Coast (Cote d’Ivoire)
North Korea
Syria
Regime / List Based
Balkans/Yugoslavia
Belarus
Congo (Democratic Republic)
Liberia
Iraq
Zimbabwe
Please see Sanctioned Countries Chart (pdf) for specific details.
Further program information is available on the OFAC Sanctions Programs website.
Types of Sanctions
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.”
Osama Bin Laden:a "Specially Designated National" Specially Designated Nationals and Blocked Persons
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.