Restricted Parties
The U.S. Government maintains lists of denied entities or restricted parties with whom US universities are restricted in their interactions with; these lists include not only businesses and organizations but individuals as well. Further, the nature of the denials or restrictions vary depending on the regulating agency and the nature of debarment.
Additionally, the Fundamental Research Exclusion (FRE) may not apply to denied or restricted parties. It is important that, prior to collaborating with a foreign entity, you ensure they are not listed on a denied or blocked parties list. To do this, complete a Restricted Parties Screening Request.
In the event the individual or entity appears on one of the lists, additional due diligence may be needed before proceeding.
Embargoed & Sanctioned Countries
The United States’ Office of Foreign Assets Control (OFAC) regulates the U.S. embargo and sanctions programs that restrict or prohibit different interactions with certain countries, with the level of restrictions varying depending on the destination country and the proposed interaction. Additionally, OFAC regularly updates its lists of embargoed and sanctioned countries to reflect the United States’ current foreign policy and global relations. For an updated list of currently sanctioned countries and programs see the OFAC Sanctions Programs and Country Information.
OFAC’s sanction programs include three categories:
- “Comprehensive” – Virtually all interactions and activities are prohibited, including exporting to, importing from, financial transactions of any kind, and/or providing services of any kind, without an authorized export license.
- “Limited” – Only some activities (e.g., importation of items) are prohibited.
- “Regime or List-Based” – Targeted against specific individuals or specific groups usually associated with a governmental body or regime.
Countries of Concern
Apart from considering US embargoes and sanctions against certain countries, careful consideration should also be given when collaborating with a potential country of concern. While some countries may not be prohibited from scholarly interactions or export activities, there may still be risk involved related to research security, cybersecurity, and personal safety. VEC can help you identify such factors that could hinder your international collaborations and determine the best way forward for your research endeavors.