Embargoes & Sanctioned Countries

The Office of Foreign Assets Control (OFAC) enforces all U.S. embargoes and sanction programs. Depending on the sanction/embargo program, different activities may or may not be prohibited without a specific government authorization or license.

OFAC does not per se regulate access to specific laboratory equipment, technical data and research results the way that the EAR and ITAR do. Rather, OFAC regulations govern financial transactions and certain services with embargoed and sanctioned countries, entities, and individuals. Examples of OFAC-governed transactions include (but are not limited to):

• Making payments to or receiving money from individuals or entities subject to embargoes and/or sanctions
• Receiving gifts from a donor or other party that is a restricted party, or is a national of a sanctioned country
• Collaborating with an institution in Iran (even if only data is transferred)
• Transferring commodities or materials to an OFAC-restricted country
• Importing items (including artwork, artifacts, books, etc.) from a sanctioned country
• Providing editorial comments directly to a foreign national located in an OFAC-restricted country as part of a journal or peer review
• Advising on procurement or laboratory-set up activities; or research methodologies
• Travel to Iran for any professional purpose (e.g. conference, research, teaching)

OFAC sanction programs can be generalized into three categories:

• “Comprehensive” – In general, under comprehensive sanctions programs, ALL interactions and activities are prohibited, including exporting to, importing from, financial transactions of any kind, and/or providing services of any kind. While essentially all interactions with comprehensively sanctioned countries are prohibited, there is an exception for informational materials that allows certain transactions to occur. Currently, the “comprehensively” sanctioned countries include Cuba, Iran, Syria, and North Korea.
• “Limited” – Under limited sanctions programs only some activities (e.g. importation of items) are prohibited.
• “Regime or List-Based” – Regime or List-Based sanctions are targeted against specific individuals identified by the Treasury Department and referred to as Specially Designated Nationals (SDNs) or are targeted against specific groups of people usually associated with a governmental body or regime.

For additional information on a specific sanction program, see OFAC Sanction Program Summaries.

If you don’t know whether your transaction or engagement is subject to OFAC regulations, the Export Office can help! Likewise, if you wish to engage with an individual who is based in a sanctioned country or an individual who is a restricted party, please contact us as soon as possible.