Butler Library

International Research/Export Control

Export Control and other Regulations

Sanctioned Countries & Restricted Parties

Sanctions & Restricted Party Lists

Certain entities and individuals are subject to sanctions or other restrictions under U.S. law.  These restrictions apply to both domestic and foreign entities and individuals and may restrict your ability to engage in a project, collaboration or other transaction with that entity or individual.  Columbia’s online screening tool, Visual Compliance, allows you to quickly determine whether an entity or individual is listed on a Restricted Party List.  If you are considering entering into a transaction with an entity or individual listed on a Restricted Party List, immediately contact Columbia’s Research Export Control Officer.

For information regarding opening a Visual Compliance account, please contact Columbia’s Research Export Control Officer.

OFAC Sanctions Programs

The U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) maintains sanctions against certain countries, industries, entities and individuals.  Certain countries are subject to comprehensive sanctions, while others are subject to targeted sanctions.  Comprehensive sanctions prohibit transactions with a country’s government and virtually all other transactions, including exports/imports, involving the sanctioned country.  Targeted sanctions prohibit transactions with specified industries, entities, or individuals listed on OFAC’s Specially Designated Nationals and Blocked Parties List or Consolidated Sanctions List (collectively, “SDNs”).  Columbia University and its personnel are prohibited from engaging in transactions with SDNs without prior government authorization to do so. 

Comprehensive sanctions:  Crimea, Cuba, Iran, North Korea, Sudan, Syria  

Targeted sanctions:  Balkans, Belarus, Burma (Myanmar), Central African Republic, Cote d’Ivoire, Democratic Republic of the Congo, Iraq, Lebanon, Liberia, Libya, Somalia, South Sudan, Ukraine / Russia, Venezuela, Yemen, Zimbabwe


Although restrictions vary among sanctions programs, the following transactions are generally prohibited without an OFAC license -

·         entering into contracts, agreements or research collaborations with SDNs

·         making payments to or receiving payments from SDNs

·         providing services / training to or receiving services / training from SDNs.

 

In addition to the above, exporting or importing items, information, or software to or from a sanctioned country may require a license from OFAC, the Commerce Department’s Bureau of Industry and Security, or both. 

 

If you propose to engage in any sort of transaction with an SDN, please contact Columbia’s Research Export Control Officer.

Failure to comply with U.S. sanctions regulations may result in substantial penalties.  Criminal penalties for willful violations can include fines ranging up to $20 million and imprisonment of up to 30 years.  Civil penalties for violations can include fines ranging up to $1,075,000 for each violation.

For a complete list of OFAC’s current sanctions programs, see OFAC’s
Sanctions Program and Country Summaries website.

Other U.S. Restricted Party Lists

In addition to OFAC, other U.S. Government Agencies maintain Restricted Party Lists.  Entities and individuals who appear on these lists are “restricted parties” and certain transactions with these restricted parties are prohibited.  It is important to check these Restricted Party Lists prior to engaging in a transaction.  Columbia University and its personnel are prohibited from engaging in certain transactions with restricted parties without prior government authorization to do so. 

Engaging in prohibited transactions with parties included on Restricted Party Lists can result in significant civil and criminal penalties, including fines, debarment, and imprisonment.  

If the entity or individual with whom you intend to deal is a restricted party, contact Columbia’s Research Export Control Officer.

Restricted Party Screening using Visual Compliance

Columbia’s online screening tool, Visual Compliance, allows you to quickly determine whether an entity or individual appears on OFAC’s SDN List, OFAC’s Consolidated Sanctions List, or other U.S. Restricted Party List.  Guidance on how to perform a restricted party screening is available here.

Where to Go for Help

Contact Columbia’s Research Export Control Officer-

·         If a transaction/ project involves activities in a country subject to comprehensive or targeted sanctions

·         If a transaction/ project involves transactions with an entity or individual listed on OFAC’s SDN List, Consolidated Sanctions List, or other U.S. Restricted Party List

·         For questions regarding opening a Visual Compliance account or conducting restricted party screenings