Trade Sanctions

The Foreign Assets Control Regulations prohibit unauthorized financial and other transactions with embargoed countries, and entities identified on the Specially Designated Nationals (SDN) List.

Countries Subject to Trade Sanctions

Countries subject to comprehensive embargoes are:

• Cuba
• Iran
• North Korea
• Crimea region of Ukraine
• Syria

It is generally unlawful to export or import goods, services, and money to or from these countries. In addition, there are often restrictions on travelling to these destinations. Be sure to consult with the export controls officer before engaging in any activities—including travel—in connection with embargoed countries.

It is permissible to host and teach a student or researcher visiting from an embargoed country who is in the US on a visa (provided the studies or research activities do not involve the unauthorized disclosure of EAR- or ITAR-controlled technical data). University personnel must take care, however, not to export any sort of goods, services, or money to the individual after he or she returns to his or her home country.

SDN List

The SDN List is the U.S. Government’s official list of the bad guys—terrorists and terrorist organizations, drug kingpins and cartels, human rights abusers, entities of proliferation concern, etc.  It is generally unlawful to engage in any sort of transaction with parties on the SDN absent specific approval from the U.S. Government.  In order to ensure that the University does not deal with entities on the SDN List, the Sponsored Projects Administration (SPA) screens new award subrecipients, the University’s Purchasing department screens new vendors, and the Export Controls Officer screens non-U.S. parties to international outgoing material transfer agreements.

The Foreign Assets Control Regulations are administered by the Office of Foreign Assets Control, U.S. Department of the Treasury, and are found at Title 31, Code of Federal Regulations, Parts 500-598.