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Export Compliance > Restricted Parties & Countries of Concern

COUNTRIES OF CONCERN

Restricted Parties

Certain organizations and individuals are subject to sanctions, embargoes, and other restrictions under U.S. law. Before you transact with any person or organization, use the screening tool at http://apps.export.gov/csl-search to ensure they are not a blocked or sanctioned entity.

Please contact vec@vanderbilt.edu with any questions on screening or if the person or organization searched is listed as a restricted party.

Countries of Concern

The Office of Foreign Assets Control (OFAC) is responsible for enforcing all U.S.embargoes and sanction programs. Depending on each country’s embargo or sanction program, different activities may or may not be prohibited without a specific government authorization or license.

For information on controls for all countries, see the Commerce Country Chart published by the Bureau of Industry and Security. For information on foreign nationals, vessels, or other entities, use the OFAC Sanctions List Search resource published by the Department of the Treasury.

The OFAC sanction programs can be generalized into three categories:

  • “Comprehensive” – 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.
  • “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 an updated list of currently sanctioned countries and programs see the OFAC Sanctions Programs and Country Information.

For information on controls and reasons for the controls for each country, see the Commerce Country Chart published by the Bureau of Industry and Security.

Embargoed Countries Best Practices

Going to an embargoed country?

The Department of Treasury, Office of Foreign Assets Control (OFAC) broadly regulates and restricts transactions with embargoed countries including certain academic collaborations and exchange of research materials and equipment. The most comprehensive controls apply to: China, Cuba, Iran, North Korea, Russia, Sudan, and Syria. The regulations are country/region specific.

 

For more information on a specific country:


China

Travel to China is not prohibited and it is not a sanctioned country. However, cyber security is a large concern. U.S. travelers are believed to be priority targets for cyber-attack, particularly if they are known to be engaged in classified or proprietary research in a STEM (science, technology, engineering and mathematics) discipline. Devices taken across international borders may be subject to involuntary official governmental review and even complete duplication.

 

In addition, China does not allow the import/export of encrypted devices per the State Council Directive No. 273, Regulations on the Administration of Commercial Encryption. This regulation banned foreign encryption products, deemed all commercial encryption standards a state secret, and required that commercial encryption products only be produced and sold by units designated by the relevant government authorities: The State Encryption Management Bureau and the Office of State Commercial Cryptography Administration. The rules also required that the strength of encryption systems not surpass a level set by the state regulator.


General Don'ts Regarding China

  • Do not use your regular email account. Do not send any sensitive messages via email.

  • Avoid making or receiving voice calls, using voice mail, using IM or SMS, or sending or receiving faxes.

  • Do not use USB-based public battery charging stations; the USB interface to your device they may allow the charging station to do more than just provide power.

  • Do not purchase new hardware while traveling; Do not purchase or download any new software while traveling.

  • Do not have any of your electronic devices “repaired” or “worked-on” while abroad.

If arrested, taken into custody, or interrogated, do not make any statements or sign any documents, particularly if they are written in a language you don’t know. Ask to have the U.S. Embassy or Consulate notified of your detention at once.

 

If you are considering travel to China, contact Vanderbilt Export Control as soon as possible to get an export control review of your plans and the types of items you would like to take so we can determine if any licenses would be required.

Cuba

Although travel to Cuba is a hot topic in the news, it is still prohibited under most circumstances by U.S. State Department regulations.  The recent change provides an exception under the Office of Foreign Assets Control (OFAC) general license for

“Full time professionals whose travel transactions are directly related to attendance at professional meetings or conferences in Cuba organized by an international professional organization, institution, or association that regularly sponsors such meetings or conferences in other countries. The organization, institution, or association sponsoring the meeting may not be headquartered in the U.S. unless it has been specifically licensed to sponsor the meeting.”

It is very important that you check with OFAC to ensure that your conference or business purpose qualifies under the general license and/or a specific license. In addition, it is very important to note that while you may be authorized under the general license to travel to Cuba this does not automatically allow for the import of certain types of goods and or the provision of services.  Additionally, there may be specific license requirements for equipment that you might need to take (e.g., laptop computers, cell phones, flash drives, other wireless/encryption technology, and other items). Cuban FAQs.


If you are considering travel to Cuba, contact Vanderbilt Export Control as soon as possible to get an export control review of your plans and the types of items you would like to take so we can determine if any licenses would be required.

Here is a link to the OFAC summary information on travel restrictions to Cuba along with information on who to contact if you have questions or need additional information.

Iran

Travel to Iran is not prohibited.  However, prohibited transactions include exportation, re-exportation, sale or supply of goods, technology, or services to Iran.  “Services” is broadly construed to mean providing anything of value, even if no money is exchanged.

Examples might be:

  • Providing technical assistance to an Iranian national in Iran or an Iranian institution

  • Providing unpublished data or research results to a person or institution in Iran

  • Teaching or lecturing as a guest of an institution in Iran

  • Conducting surveys and interviews inside Iran

OFAC publishes country-specific guidance on regulatory interpretation, but such guidance is not comprehensive. The Iranian Sanctions are updated frequently through publications to the Federal Register. If you are contemplating a collaboration with or research in Iran there may be licensing requirements. Licensing for Iran will take months to obtain approval and shipments or research timelines may be impacted.


General Don'ts regarding Iran: 

  • Provide technical assistance or analysis to Iranian nationals that reside in Iran or to Iranian institutions that would constitute a “service” without an OFAC license.

  • Travel to Iran and bring anything other than personal belongings (note that if personal belongings include a controlled item, the item would still require a license) or equipment covered by an OFAC license. University owned equipment or material may require a specific export license.

  • Import from Iran or Export to Iran (apart from personal items you bring for personal use during travel) anything outside of informational materials or humanitarian donations without an OFAC license.

  • Transfer funds to Iranian financial institution or to an individual or entity on one of the government restricted party lists.

If you are considering travel to Iran, contact Vanderbilt Export Control as soon as possible to get an export control review of your plans and the types of items you would like to take so we can determine if any licenses would be required.

North Korea

Travel to North Korea is generally not prohibited but if you plan to travel to North Korea, it is strongly recommended to consult the U.S. Department of State travel web page regarding such travel.


General Don’ts regarding North Korea:

  • U.S. persons are generally prohibited from engaging in transactions or dealings involving persons whose property and interests in property are blocked pursuant to North Korea-related authorities.

  • Although OFAC does not prohibit exports to North Korea per se, exports of goods and services to North Korea are generally subject to export controls administered by other agencies, including the Department of Commerce’s Bureau of Industry and Security (BIS). A license is required for the export or re-export to North Korea of almost all items (all items subject to the EAR other than food or medicines designated as EAR99).

Here is a link to the OFAC summary information on the North Korea sanctions program. If you are planning to travel to North Korea, you must consult the University’s Export Control Officer to determine if any licenses would be required.

Russia

Travel to the Russian Federation is not prohibited, but the current status of Crimea prevents official Americans from traveling to that area.

General Licenses may be issued for the following transactions:

  • The exportation or reexportation of certain agricultural commodities, medicine, medical supplies, and replacement parts from the United States or by a U.S. person, wherever located, to the Crimea region of Ukraine;

  • Noncommercial, personal remittances by U.S. persons to or from the Crimea region of Ukraine, or for or on behalf of a person ordinarily resident in the Crimea region of Ukraine;

  • The operation of certain accounts in a U.S. financial institution for an individual ordinarily resident in the Crimea region of Ukraine;

  • Certain transactions with respect to the receipt and transmission of telecommunications and mail involving the Crimea region of Ukraine; and

  • The exportation or reexportation of certain services and software from the United States or by a U.S. person, wherever located, to the Crimea region of Ukraine.

 

In considering cyber security, U.S. travelers are believed to be priority targets for cyber-attack as well as monitoring/surveillance, particularly if they are known to be engaged in classified or proprietary research in a STEM (science, technology, engineering and mathematics) discipline. Devices taken across international borders may be subject to involuntary official governmental review and even complete duplication.

 

In addition, Russia does not allow the importation/exportation of encrypted devices. Russia also requires advance approval to bring in satellite telephones. Global Positioning System (GPS) and other radio electronic devices, and their use, are subject to special rules and regulations in Russia.

 

A note on the North Caucasus Region:

Civil and political unrest continues throughout the North Caucasus region including Chechnya, North Ossetia, Ingushetia, Dagestan, Stavropol, Karachayevo-Cherkessiya, and Kabardino-Balkariya. Local criminal gangs have kidnapped foreigners, including U.S. citizens, for ransom. Do not travel to Chechnya or any other areas in the North Caucasus region. If you find yourself residing in these areas depart immediately.

General Don'ts regarding Russia: 

  • Transfer, pay, export, withdraw, or otherwise deal in the property or interests in property of an entity or individual listed on OFAC’s SDN List

  • Directive 4 prohibits providing, exporting, or reexporting, directly or indirectly, goods, services (except for financial services), or technology in support of exploration or production for deep-water, Arctic offshore, or shale projects that have the potential to produce oil in the Russian Federation, or in maritime area claimed by the Russian Federation and extending from its territory, and that involve any person subject to Directive 4, its property, or its interests in property.

  • Importation/exportation, directly or indirectly, of any goods, services, or technology from the Crimea region of Ukraine is prohibited.

Sudan

Travel to Sudan is not prohibited. However, many transactions, including the provision of certain services, is prohibited or requires a license.

The following transactions are allowed under a General License:

  • donations of articles intended to relieve human suffering, such as food, clothing, and medicine;

  • the importation from and exportation to Sudan of information and informational materials whether commercial or otherwise, regardless of format or medium of transmission;

  • certain academic and professional exchanges with Sudan.

General Don'ts regarding Sudan:

  • The importation to and exportation from the U.S. of goods and services is generally prohibited. Specifically, the following is prohibited:
    • The importation of goods and services of Sudanese origin;

    • The exportation and re-exportation to Sudan of goods, technology, or services from the U.S. or by a U.S. person;

    • The performance by a U.S. person of any contract in support of an industrial, commercial, public utility, or governmental project in Sudan

Note that on July 9, 2011, Southern Sudan gained its independence, becoming the new Republic of South Sudan, and was formally recognized by the United States Government. As of July 9, 2011, therefore, the Republic of South Sudan is no longer subject to the Sudanese Sanctions Regulations

Here is a link to the OFAC summary information on the Sudan sanctions program. If you are planning to travel to/research in Sudan, you must consult the University’s Export Control Officer to determine if any licenses would be required.

Syria

Travel to Syria is generally allowed although not advised. If you are planning to travel to Syria, please consult the U.S. Department of State website.


General Don’ts regarding Syria:

  • You cannot directly or indirectly export, re-export, sell or supply any services to Syria with the exception of exports and re-exports of services in support of humanitarian and other not-for-profit activities in Syria by U.S. and third-country non-governmental organizations.

Here is a link to the OFAC summary information on the Syria sanctions program. If you are planning to travel to/research in Syria, you must consult the University’s Export Control Officer to determine if any licenses would be required.

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