Overview: The US government maintains multiple “Sanctions Programs” which prohibit certain transactions with specified countries. The types of prohibited activities vary by country and change frequently due to changes in foreign policy and international relations. Most of the sanction programs target very specific activities. However, some countries are subject to “comprehensive sanctions” which are blanket prohibitions on exports and services to or from.
Comprehensive Sanctions: At the time of this guidance release (July 2022), the countries and regions with comprehensive sanctions are:
- North Korea
- Ukraine (Crimea, Donetsk, Luhansk, and Sevastopol regions only)
*Note on Russia: As of July 2022, Russia is not under comprehensive sanctions but there are numerous sanctions targeted at specific individuals, institutions, and activities including transfer of funds.
Sanctioned Activities: Each sanctions program has different prohibitions and exceptions so it is not possible to provide blanket guidance with enough detail to cover every country or scenario. In some cases, it is possible to obtain licenses from OFAC to conduct an activity that would otherwise be prohibited. If you have plans to participate in any of the following activities with the countries called out above, please contact the Export Compliance Office as soon as possible:
- Collaborating in research* with individuals and entities inside of sanctioned countries.
- Sending and receiving items and research information to or from individuals inside of sanctioned countries.
- Temporary travel with university equipment.
- Academic “study abroad” programs.
- Presenting at conferences hosted by a sanctioned country, even if virtual.
- Participating in distance education from inside of a sanctioned country, either as a student or instructor.
- Performing or receiving services such as surveys or collection of specimens.
- Transferring funds to or from a sanctioned country.
*Note: Collaborations with students and visiting scholars who are citizens of sanctioned countries are not generally prohibited by sanctions if the collaborations occur inside the US and the student or visiting scholar is acting within the scope of their visa.
Electronic communications with sanctioned countries: Personal communications with individuals inside sanctioned countries are not restricted by any of the sanctions programs. However, some IT service providers have restricted services to sanctioned countries by IP address to avoid inadvertently facilitating prohibited transactions. Division of IT has provided more information on restricted IT services here.