Restricted Parties & Countries of Concern
Not only can sanctions apply to countries and governments, they can also apply to people and organizations. The U.S. Government maintains listings of denied parties and we are restricted in our interactions with individuals and entities on those lists. Restrictions vary depending on the regulating agency and nature of debarment.
Did you know, the Fundamental Research Exclusion (FRE) may not apply to restricted parties? Before you transact with any person or organization, ensure they are not listed on a denied or blocked parties list.
- Ask VEC to screen for you - complete a Restricted Parties Screening Request
- Conduct your own screening - use the Consolidated Screening List at export.gov.
In the event the individual or entity appears on one of the lists, contact firstname.lastname@example.org. Additional due diligence may be needed before proceeding.
Countries of Concern
The Office of Foreign Assets Control (OFAC) regulates the U.S. embargo and sanctions programs. These programs restrict or prohibit different interactions with certain countries. The level of restriction can vary depending on the destination country and the proposed interaction, as well as our Government’s current foreign policy and international relations.
The OFAC sanction programs can be generalized into 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.
- North Korea
- “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 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.
Going to an embargoed country?
The Department of Treasury, Office of Foreign Assets Control (OFAC) broadly regulates and restricts interactions with embargoed countries. Regulations vary depending on the country or region and change frequently due to economic policy and national security. But the most comprehensive controls apply to: Cuba, Iran, North Korea, Sudan, and Syria. Most travel and transactions require an export license to these destinations which can affect your research and educational relations.
Additionally, travel to certain countries, while not prohibited, should have special considerations for security risk. China and Russia travelers may experience a range of cyber security issues that deserve mention.
For more information on a specific country:
Travel to the People’s Republic of China or the Russian Federation is not prohibited. 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. Electronic devices taken may be subject to involuntary governmental review and even complete duplication. They may also be successfully attacked and compromised without the user even knowing.
China does not allow the import 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 only be produced and sold by government authorities. An example of prohibited encryption is Virtual Private Network (VPN).
Russia has similar restrictions on the import 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.
- Send any sensitive messages via email or access sensitive data.
- Open attachments, click unknown links, connect unknown USB devices or CDs.
- 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.
- Purchase new hardware while traveling; Do not purchase or download any new software.
- Have any of your electronic devices “repaired” or “worked-on” while abroad.
- Ensure your system is fully patched and has all institutionally recommended security software installed.
- Be aware your internet activity may be monitored.
- Power down your device whenever possible.
- Upon return, have your device inspected for compromise before hooking in to the Vanderbilt network.
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 or Russia, 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.back to top
Travel to Cuba is a hot topic in the news. On June 16, 2017, it was announced that travel to Cuba is still prohibited under most circumstances by U.S. State Department regulations. There are 12 categories under which travel from the U.S. to Cuba is still permitted. Some are listed here:
- Educational activities for credit towards a degree
- Educational activities not for credit towards a degree when organized by a US entity and accompanied by an employee or agent of that entity
- Professional research and professional meetings
- Public performances, workshops, clinics, competitions, and exhibitions
The ban on tourism remains in place. Travelers must maintain a full-time schedule of activities related to an authorized travel category and must maintain records of their activities (itinerary, receipts, etc.). Expect increased scrutiny at the US border when traveling to or from Cuba.
Travelers will also be prohibited from engaging in travel-related transactions with entities owned or controlled by Grupo de Administración Empresarial (GAESA). The U.S. State Department will be issuing a list of GAESA entities, which may include hotels, restaurants, and various service providers a traveler may encounter.
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, certain goods and the provision of services are prohibited. Note: Shipping or hand-carrying any items (and certain technology or software) to Cuba remains subject to strict export control restrictions. 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.back to top
Travel to Islamic Republic of Iran is not prohibited. However, many interactions are sanctioned and require an export license. A restriction of note for researchers is providing a “service”. “Service” is construed to mean providing anything of value, even if no money is exchanged.
Examples might be:
- Providing technical assistance to an Iranian national or an Iranian institution
- Presenting data or research results to a person or institution
- Teaching or lecturing as a guest of an institution
- Attending a conference
In addition, Iranian authorities continue to unjustly detain and imprison U.S. citizens, including students and academics on charges of espionage. The U.S. government does not have diplomatic or consular relations with the Iran and therefore cannot provide protection or routine consular services to U.S. citizens in Iran.
Provide technical assistance or analysis to Iranian nationals or institutions that would constitute a “service” without an OFAC license.
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 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.
The Iranian Sanctions are updated frequently, but the Department of Treasury provides additional guidance on their website. If you are considering travel to Iran, contact Vanderbilt Export Control immediately, regardless if your trip purpose is professional or personal.back to top
On August 2, 2017, the Department of State published a notice that prohibits the use of U.S. passports for travel to the Democratic People's Republic of Korea (North Korea). The restriction will go in to effect on September 1, 2017 and it will be required to get "special validation" to travel to this destination. It is strongly recommended to consult the U.S. Department of State travel web page regarding travel to North Korea.
General Information ...
- 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, 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).
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.
Here is a link to the OFAC summary information on the Sudan sanctions program. If you are planning to travel to/research in the Sudan, you must consult Vanderbilt Export Control to determine if any licenses would be required.back to top
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.You cannot export, re-export, sell or supply any services to Syria without an export license, with the exception of exports and re-exports of services in support of humanitarian and other not-for-profit activities.
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 Vanderbilt Export Control to determine if any licenses would be required.back to top