U.S. Department of the Treasury
Regulatory Authority and Scope
The Department of the Treasury, through the Office of Foreign Assets Control (OFAC), administers and enforces economic and trade sanctions against known terrorists, narcotics traffickers, and proliferators of weapons of mass destruction named on the Specially Designated Nationals & Blocked Persons List, and against targeted foreign countries and regimes that are hostile to the U.S. as identified on the Country Sanctions List.
The scope of the sanctions in each program depends on the country and is subject to frequent change based on the changing geo-political landscape. Comprehensive sanctions programs are wide reaching and control all imports, exports, and the provision of services related to individuals who are citizens of sanctioned countries. Selective sanctions target specific individuals and entities in or associated with a specific country or regime.
U.S. persons may not engage in prohibited transactions or activities unless authorized by OFAC or allowed under a general license, specific license, or exemption.
Examples of activities related to sanctions that may require a license include:
- Import of items from the sanctioned country (for instance, samples extracted for analysis).
- Export, reexport, sale or supply of items or technology to the sanctioned country (for instance, research samples).
- Transfer of funds to or from the sanctioned country (for instance, an honorarium paid to a guest speaker).
- Import or export of a service. A service is generally understood to include providing anything of value (for instance, human subjects research involving surveys, and providing technical assistance with a research question).
- Facilitation of transactions with the sanctioned country or attempting to evade the regulations (for instance, a researcher may not send a sample to a colleague in France in order to have that colleague send the sample to a researcher in a sanctioned country).
- Attending a conference in a sanctioned country.
OFAC Licensing for Country Based Programs
It is important to review the specific sanctions program before conducting activities with an OFAC sanctioned country or person, or in an OFAC-sanctioned country. The individual sanctions specifically describe what activities are exempt from the embargo (for instance, personal communications, exchange of informational materials, etc.) as well as what activities may be permitted under an applicable license. Activities that are permitted under a general license do not require specific permission from OFAC prior to engaging in the activity; however, the conditions of a general license must be carefully reviewed and the use of the general license documented. Activities that do not fall under an available license may be eligible for a specific license from OFAC. Specific license requests must be submitted and approved by OFAC prior to engaging in the sanctioned activity. Contact the Export Control Officer in Sponsored Projects when considering any proposed OFAC sanctioned activity.