Foreign Assets Control Regulations
The Foreign Assets Control Regulations prohibit unauthorized financial and other transactions with sanctioned countries or regions, as well as entities identified on the Specially Designated Nationals (SDN) List.
Countries or Regions Subject to Trade Sanctions
Countries subject to strict trade sanctions are:
- Crimea, Donetsk, and Luhansk regions of Ukraine
- North Korea
It is generally unlawful to export or import certain goods, services, technologies, and money to or from these locations. In addition, there are often restrictions on traveling to these destinations. Be sure to consult with the export controls officer before engaging in any activities—including travel—in connection with sanctioned countries or regions.
It is permissible to host and teach a student or researcher visiting from an embargoed location who is in the U.S. 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.
The SDN List is the U.S. Government’s chief 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 (among other restricted parties lists), the Office of Sponsored Projects Administration (SPA) screens new award subrecipients, the University’s Purchasing department screens new vendors, and the Export Controls Office screens non-U.S. parties to international external sales and 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.