Generally, collaborations between university personnel and scholars at foreign institutions or organizations do not require export licenses unless they involve export-controlled or restricted research, or involve scholars from sanctioned countries. Before engaging in international collaborations, the University needs to determine if export licenses are required and to verify that the foreign individuals and/or organizations are not blocked or sanctioned by the U.S. government.
U.S. Embargoes and Sanction Programs
The Office of Foreign Assets Control (OFAC) is responsible for enforcing all U.S. embargoes and sanction programs. Depending on each country’s embargo or sanction program, different activities may or may not be prohibited without a specific government
authorization or license.
The OFAC sanction programs falls into three categories:
- Comprehensive Sanctions. In general, under comprehensive sanctions programs, ALL interactions and activities are prohibited, including exporting to, importing from, financial transactions of any kind, and/or providing services of
any kind. While essentially all interactions with comprehensively sanctioned countries are prohibited, there is an exception for informational materials that allows certain transactions to occur. See Informational Materials and Publishing Activities.
- Limited Sanctions. Under limited sanctions programs only some activities (e.g., importation of items) are prohibited. Regime or
- List-Based Sanctions. Regime or List-Based sanctions are targeted against specific individuals identified by the Treasury Department and referred to as Specially Designated Nationals (SDNs) or are targeted against specific groups
of people usually associated with a governmental body or regime.
The table below outlines the countries currently under U.S. sanction along with an indication of the sanction program in place. For additional information on a specific sanction program see OFAC Sanction Program Summaries.
Informational Materials and Publishing Activities
OFAC has granted a general license that specifically allows for activities in support of publishing and/or marketing of informational materials with sanctioned countries Iran, Cuba, Sudan, and Burma [see Federal Register volume 72, 50047-50052]. The general license authorizes U.S. persons to freely engage in activities that are “necessary and ordinarily incident to the publishing and marketing of manuscripts, books, journals, and newspapers in paper or electronic format…”. This general license allows university personnel to participate in any activity that is part of the normal academic peer-review or publishing process. However, it does not allow for these activities to occur if the foreign person(s) involved is a governmental official, or represents or is working on behalf of the government of the sanctioned country. For the purposes of this license, academic and research institutions and their personnel are not considered governmental employees or their representatives. It is important to note that this general license does not allow for or authorize the provision of any customized or consulting services. Such activities would still require a separate governmental authorization or license.