U.S. Embargoes and Sanction Programs
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. Some programs are comprehensive in nature and block the government and include broad-based trade restrictions, while others target specific individuals and entities.
The OFAC sanction programs can be generalized into two categories:
- In general, under comprehensive sanctions programs, 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. See Publishing & Marketing General License.
- Under limited sanctions programs only some activities (e.g., importation of items) are prohibited. 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.
A number of the named individuals and entities on the Specially Designated Nationals (SDN) and Blocked Persons List are known to move from country to country and may end up in locations where they would be least expected. U.S. persons are prohibited from dealing with SDNs wherever they are located and all SDN assets are blocked. Entities that a person on the SDN List owns (defined as a direct or indirect ownership interest of 50% or more) are also blocked, regardless of whether that entity is separately named on the SDN List. Because OFAC’s programs are dynamic, it is very important to check with the University Export Control Official for screening of all foreign nationals or foreign organizations you are considering working with.
Below is a table of the countries currently under U.S. sanction along with an indication of the sanction program in place. For additional information on a specific sanction program see OFAC Sanction Program Summaries.
|Syria||Central African Republic||Ukraine-/Russia|
|Congo (Democratic Republic)||Venezuela|
|China||Ivory Coast (Cote d’Ivoire)||Zimbabwe|
TRAVEL TO CUBA
Updated regulations related to Cuban Assets Controls Regulations have been provided by the Department of Treasury as of 6-6-19: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/cuba_fact_sheet_20190604.pdf Cuba 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 work with the university ECO and 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. There are specific limitations on how much and on what things you can spend money on while in Cuba, and you will want to make sure that you are staying within the proscribed spending amounts (see State Department’s Travel Per Diem Allowances for Foreign Areas). 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).
OFAC has summary information on travel restrictions to Cuba along with information on who to contact if you have questions or need additional information: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/cuba.aspx.
If you are considering travel to Cuba, contact the University’s Export Control office at firstname.lastname@example.org or (336) 256-1173 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.
*Effective Sept. 24, 2020, persons subject to U.S. jurisdiction (U.S. Persons) are generally prohibited from lodging, paying for lodging, or making any reservations for or on behalf of a third party to lodge at any property that the U.S. Secretary of State identifies as owned or controlled by the Cuban government, a prohibited official of the Government of Cuba, a prohibited member of the Cuban Communist Party, or a close relative of these.
 Effective 1-26-2016: OFAC is expanding an existing general license to authorize certain additional travel-related transactions as are directly incident to the conduct of market research; commercial marketing; sales or contract negotiation; accompanied delivery; installation; leasing; or servicing in Cuba of items consistent with the export or reexport licensing policy of the Department of Commerce, provided that the traveler’s schedule of activities does not include free time or recreation in excess of that consistent with a full-time schedule. https://www.treasury.gov/resource-center/sanctions/Programs/Documents/fact_sheet_01262016.pdf
 While China is not a sanctioned country under OFAC, there are some Export Control concerns from the State and Commerce Departments. Several Chinese entities are on the Special Designated lists, and any visits or collaborations will need to be thoroughly vetted through the ECO. Additional information from the State Department can be found at: http://www.state.gov/r/pa/ei/bgn/18902.htm