International Research/Export Control
Export Control and other Regulations
U.S. Sanctioned Countries and Specially Designated Nationals
The Treasury Department’s Office of Foreign Asset Control (“OFAC”) administers and enforces economic sanctions imposed by the United States against foreign countries. These sanctions may require obtaining OFAC approval before conducting research or other activities in or involving the sanctioned country. Some sanctions regimes are more restrictive than others, and apply to the whole country, while other regimes are more targeted against certain individuals or entities in a country. Currently, sanctioned countries include the following (most restrictive sanctions regimes are in bold):
Central African Republic
Cote D’Ivoire (Ivory Coast)
Democratic Republic of Congo
Liberia (Former Liberian Regime of Charles Taylor)
The list of sanctioned countries is updated periodically and is available at http://www.treasury.gov/offices/enforcement/ofac/programs/index.shtml. Any project involving activities in an OFAC-sanctioned country must be reviewed by the University’s International Research Committee.
OFAC can also designate persons and entities (including persons and entities in the United States) as “Specially Designated Nationals” or “SDNs.” OFAC designates persons and entities as SDNs for narcotics trafficking, weapons proliferation and other reasons. The University, its personnel and U.S. persons are prohibited from engaging in transactions with SDNs, and property of SDNs must be “blocked.”
The SDN list appears on OFAC’s website at www.treas.gov/offices/enforcement/ofac/sdn/ and is updated regularly. When entering into discussions with a proposed collaborator, it is critical to check the SDN list for the name of the person or entity with which you are dealing. OGC and ORCT can provide guidance on how to complete such checks.