Office of Foreign Assets Control (OFAC) Regulations

Overview

The Office of Foreign Assets Control (OFAC), part of the U.S. Department of the Treasury, administers and enforces U.S. economic and trade sanctions based on U.S. foreign policy and national security objectives.

OFAC sanctions may restrict or prohibit transactions, services, financial dealings, imports, exports, collaborations, and other activities involving sanctioned countries, governments, organizations, individuals, sectors, or other designated parties.

Sanctions programs vary significantly. Some programs impose broad restrictions involving particular countries or regions, while others target specific individuals, organizations, industries, activities, or transactions.

Although most University research is not affected by OFAC sanctions, requirements may apply to certain international research activities, collaborations, travel, shipments, financial transactions, professional services, and other University activities.

The Office of Research Security (ORS) assists faculty, staff, and students in identifying applicable OFAC sanctions requirements before an activity begins.

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OFAC Regulations at a Glance

Topic	Information
Administered By	U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC)
Primary Regulations	31 CFR Chapter V, Parts 500–599, together with applicable statutes and Executive Orders
Primary Focus	U.S. economic and trade sanctions programs
Sanctions Programs	Comprehensive and targeted sanctions involving countries, governments, organizations, individuals, sectors, and activities
May Apply To	International collaborations, travel, financial transactions, shipments, services, and other international activities

OFAC Sanctions Programs

OFAC administers numerous sanctions programs. Each program is established under specific statutory or Executive Order authority and may impose different prohibitions, restrictions, licensing requirements, or other conditions.

Sanctions programs may include:

Country- or region-based sanctions.
Counterterrorism sanctions.
Nonproliferation sanctions.
Cyber-related sanctions.
Human rights and corruption sanctions.
Narcotics trafficking sanctions.
Russia-related sanctions.
Sectoral or activity-specific sanctions.
Other targeted sanctions established under federal law or Executive Order.

Some sanctions broadly restrict transactions involving a country or region. Others apply only to designated organizations, individuals, industries, property, transactions, or activities.

Researchers should not assume that the same restrictions apply to every country, organization, or activity. The applicable requirements depend on the specific sanctions program and the circumstances of the proposed activity.

Common Considerations

OFAC sanctions are economic and trade restrictions imposed under U.S. law to advance U.S. foreign policy and national security objectives.

Depending on the applicable program, sanctions may:

Block property or financial interests.
Prohibit or restrict transactions with designated parties.
Restrict the provision or receipt of services.
Restrict financial transactions.
Restrict imports or exports.
Prohibit dealings involving particular sectors or activities.
Require prior U.S. Government authorization before an activity may proceed.

The scope and requirements of each sanctions program are different.

OFAC requirements may affect University activities involving:

International research collaborations.
International travel.
International shipments or transfers.
Financial transactions.
Payments, reimbursements, honoraria, or other transfers of value.
Research agreements and other contractual arrangements.
Consulting, teaching, training, or professional services.
Procurement of goods or services.
Sponsored research involving sanctioned parties or jurisdictions.
Activities involving sanctioned countries, organizations, or individuals.

The applicability of OFAC requirements depends on the specific country, organization, individual, transaction, activity, and applicable sanctions program.

There is no single OFAC “country list” that determines whether sanctions apply.

Some OFAC programs impose broad restrictions involving particular countries or regions, while others target specific individuals, organizations, governments, sectors, or activities regardless of location.

An activity involving a country that is not subject to broad sanctions may still be restricted if a participating individual or organization is subject to targeted sanctions.

ORS evaluates both the applicable sanctions program and the individuals and organizations involved in the proposed activity.

OFAC maintains sanctions lists identifying individuals, organizations, vessels, and other parties subject to particular sanctions.

One of the most significant is the Specially Designated Nationals and Blocked Persons List (SDN List). OFAC also maintains additional sanctions lists with different restrictions.

Activities involving a listed party may be prohibited or restricted and may require additional review before proceeding.

ORS conducts Restricted Entity Screening as part of applicable sanctions and export control reviews.

Some activities that would otherwise be prohibited may be authorized under an OFAC general license or specific license.

A general license authorizes categories of transactions when the conditions of the authorization are satisfied.

A specific license is written authorization issued by OFAC for a particular transaction or activity.

The existence of a general license does not mean that every related activity is automatically authorized. All applicable terms, limitations, recordkeeping requirements, and other conditions must be satisfied.

ORS determines whether an existing authorization may apply or whether a specific license or other U.S. Government authorization is required.

OFAC sanctions may apply even when the underlying activity is academic, educational, or research-related.

Depending on the applicable sanctions program, requirements may affect:

Research collaborations.
Research services or technical assistance.
Teaching or training.
Conferences and professional activities.
International research agreements.
Payments and reimbursements.
International shipments or transfers.
Research information, software, or technology.
Procurement of goods or services.
Travel-related transactions.

An activity does not become exempt from sanctions requirements simply because it is conducted for academic or research purposes.

At the same time, some sanctions programs contain general licenses, exemptions, or other authorizations that permit certain educational, informational, humanitarian, professional, or other activities when specified conditions are satisfied.

ORS can assist in determining what requirements and authorizations apply.

How ORS Can Help

ORS assists researchers with:

Reviewing proposed activities involving sanctioned countries, organizations, or individuals.
Identifying applicable OFAC sanctions programs.
Conducting Restricted Entity Screening.
Evaluating whether a general license or other authorization may apply.
Determining whether a specific OFAC license or other U.S. Government authorization may be required.
Reviewing international agreements, services, shipments, transfers, and transactions for sanctions concerns.
Coordinating with Sponsored Programs, Procurement, University Counsel, and other University offices, as appropriate.
Providing sanctions and export control consultations.

Related Authorities

OFAC administers sanctions programs under numerous statutes and Executive Orders.

Significant statutory authorities include:

International Emergency Economic Powers Act (IEEPA)
Trading with the Enemy Act (TWEA)
Other federal statutes authorizing particular sanctions programs

Applicable Executive Orders and federal regulations vary by sanctions program.

Researchers are not expected to determine the applicable legal authority for a proposed activity. ORS can assist in identifying the relevant sanctions requirements.

Frequently Asked Questions

Does OFAC maintain a single list of sanctioned countries?

No. OFAC administers many different sanctions programs. Some impose broad restrictions involving particular countries or regions, while others target particular individuals, organizations, industries, or activities.

Does an activity involving a sanctioned country automatically mean it is prohibited?

Not necessarily. The applicable sanctions program may prohibit the activity, permit it under a general license or exemption, or require a specific license or other authorization.

ORS should review the proposed activity before commitments are made.

Can OFAC sanctions apply to research collaborations?

Yes. Depending on the parties and activities involved, sanctions may affect collaborations, services, agreements, payments, transfers of research resources, and other research activities.

Can sanctions apply even if no money changes hands?

Yes. OFAC regulations may restrict services, collaborations, transfers, or other activities even when no payment is involved.

Can sanctions apply to individuals or organizations outside sanctioned countries?

Yes. Targeted sanctions may apply to designated individuals and organizations located anywhere in the world.

When Should I Contact ORS?

Contact ORS before:

Conducting University activities involving a sanctioned country or region.
Collaborating with an organization or individual that may be subject to U.S. sanctions.
Providing research, consulting, teaching, training, or other professional services involving sanctioned parties or jurisdictions.
Making or receiving payments involving sanctioned countries, organizations, or individuals.
Entering into an agreement involving a sanctioned party or jurisdiction.
Shipping, hand-carrying, or electronically transferring research assets involving a sanctioned destination or party.
Proceeding whenever you are uncertain whether OFAC requirements apply.

Federal Resources

For current U.S. sanctions programs, regulations, sanctions lists, licensing information, and official guidance, visit the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) website.

OFAC maintains current Sanctions Programs and Country Information, sanctions lists, general licenses, frequently asked questions, and other regulatory guidance.

Need Assistance?

If your proposed activity involves a sanctioned country or region, a potentially restricted party, an international financial transaction, or another activity that may be subject to OFAC sanctions, contact ORS before proceeding.