Export Compliance – How Sanctions and Embargoes Affect Researchers
By Jennifer Horn, Director of Export Compliance and Security
The U.S. Office of Foreign Asset Controls (OFAC) administers embargoes and sanction programs on behalf of the U.S. government. Recently you may have heard that President Obama lifted sanctions against Burma, Cote d'Ivoire, and some specific restrictions on trade with Cuba and Iran. Sanctions can be imposed or lifted by Executive Order in many cases, which means they are subject to frequent changes. The embargo against Cuba, however, was created by six different statutes, so while President Obama was able to lift some aspects of the sanctions, most of the embargo is still in place.
Comprehensive sanction programs exist against Cuba, Iran, Sudan, and Syria that would still impact university researchers. These sanctions control all imports, exports, and services provided to individuals residing in these countries.
More specific sanctions target specific individuals and entities based on the country or regime in power. A few examples are Belarus, Libya, Somalia, and Ukraine/Russia. Specific sanctions may be based on narcotics trafficking, counter terrorism, nuclear non-proliferation and even the diamond trade.
How does that impact you as a researcher? Under sanction programs you must file an exemption, have a "general license," or obtain a specific license for your activity or transaction when dealing with individuals or entities in embargoed or sanctioned countries. A list of current OFAC sanctions by country is available on the U.S. Department of Treasury website. In addition, specific individuals may be sanctioned.
Researchers may need a license from OFAC to:
- Import items such as research samples from a sanctioned country.
- Export research samples, items or technology to a sanctioned country.
- Pay an honorarium to a guest speaker by transferring funds to or from a sanctioned country.
- Provide a service or anything of value to participants in a human subjects study involving surveys or interviews.
- Provide technical assistance with a research question to a citizen of a sanctioned country.
- Attend a conference in a sanctioned country.
- Facilitate transfers of research samples to sanctioned countries for the benefit of other institutions.
In any of these situations, please check with the Office of Export and Security Compliance before proceeding. For more complete information, you can access the CITI training program available to all TTU personnel, and complete the module on "Export Compliance and United States Sanctions Programs." If you have further questions, please contact me at firstname.lastname@example.org.