Restricted Countries, Entities, and Persons
The U.S. Department of the Treasury, through its Office of Foreign Assets Control (OFAC), enforces U.S. embargo and sanction programs that may restrict transactions with certain foreign countries irrespective of whether the exported technology is controlled under the ITAR or the EAR.
Sanctions programs vary in severity. In cases where a country is comprehensively embargoed, ALL transactions are prohibited with that country, including exporting to, importing from, financial transactions with, or providing services to. Countries with comprehensive or extensive sanctions include Iran, Cuba, Sudan, Syria, and North Korea. The OFAC full list of current sanctions can be found on the OFAC website. Depending on the country’s embargo or sanctions program, certain activities may be prohibited without a government license. The Department of State also maintains country level sanctions which can be found here.
In addition, OFAC along with the Department of Commerce and Department of State maintain lists of entities (including universities and institutes) and persons with whom interactions are prohibited. These lists include the OFAC Specially Designated Nationals List, and the Commerce Department’s Entity List and Denied Persons List. A Consolidated List is available which includes the aforementioned lists and several others.
To prevent transactions with restricted entities or persons, shipping destinations, travel destinations, visitors, and international collaborators should be screened against the restricted parties lists discussed above (Restricted Party Screening).
When is RPS necessary?
Any interactions with foreign persons or entities should undergo RPS. Examples include:
- International shipment destinations
- sending or carrying equipment, biologicals, or controlled technical information overseas
- Visa applicants
- Foreign visitors
- International sponsors
- International travel destinations
When is RPS done automatically and when do I need to request it?
Visa applicants going through the Office of International Students and Scholars (OISS) routinely undergo RPS. Material Transfer Agreements going through the Office of Technology Management (OTM) are also routinely screened. If your transaction is not going through either of these offices please contact the Export Control Manager (ECM) at email@example.com to have restricted party screening conducted for you. Examples of situations where RPS should be requested:
- Faculty member receives a request to give a talk at a foreign university or institute (request screening beforetravel arrangements are made)
- An unsolicited request is received by a foreign national to tour a high technology facility (request screening beforeletter of invitation is sent).
- Items are being shipped to a foreign destination
Can I check the lists myself?
Multiple lists maintained by multiple agencies make screening complex. There is a consolidated screening list search engine available online. However the university has software which provides more comprehensive screening of these and additional lists as well as an audit trail. Please contact the ECM at firstname.lastname@example.org for RPS assistance.