Sanctions & Embargo Programs
Overview
University research and professional activities may involve countries, organizations, or individuals subject to U.S. economic sanctions or trade restrictions.
Many international activities may proceed without restriction. However, depending on the country, participating organizations or individuals, proposed activity, and applicable U.S. regulations, certain activities may be prohibited, restricted, or require prior U.S. Government authorization.
Sanctions considerations may arise in connection with research collaborations, international travel, professional activities, agreements, financial transactions, shipments and transfers, and the sharing of research information, software, or technology.
The Office of Research Security (ORS) assists faculty, staff, students, and researchers in identifying applicable sanctions, export control, research security, sponsor, and institutional requirements before engaging in activities involving sanctioned or embargoed countries.
REQUEST A SANCTIONS/export control REVIEW
Contact ORS Before You
Contact ORS before you:
- Travel to a sanctioned or embargoed country for University research or other University-related activities.
- Establish or participate in a research collaboration involving a sanctioned country, organization, or individual.
- Provide research, consulting, teaching, technical assistance, training, or other professional services involving a sanctioned country.
- Ship, hand-carry, or electronically transfer research equipment, materials, software, technology, technical information, research data, or other research assets to a sanctioned or embargoed country.
- Purchase goods or services from, make payments to, or conduct other financial transactions involving organizations or individuals in a sanctioned or embargoed country.
- Enter into a research agreement or other University agreement involving an organization in a sanctioned or embargoed country.
- Host or engage a researcher affiliated with an organization located in a sanctioned or embargoed country.
- Are uncertain whether U.S. sanctions, export control regulations, or other institutional requirements apply to a proposed activity.
Key Considerations
U.S. sanctions and export control requirements vary depending on the country or destination involved and the nature of the proposed activity.
Some activities involving sanctioned or embargoed countries may be prohibited or require prior U.S. Government authorization. Other activities may be permitted depending on the circumstances.
Researchers should contact ORS before beginning an activity involving a sanctioned or embargoed country whenever they are uncertain whether restrictions apply.
Sanctions may affect research and professional activities involving individuals or organizations in sanctioned countries.
Activities that may require additional review include:
- Research collaborations
- Sponsored research
- Conferences, meetings, or other professional activities
- Teaching or mentoring
- Consulting
- Technical assistance or training
- Visiting appointments or affiliations
- Other professional or research services
Whether an activity may proceed depends on the country, participating organizations and individuals, nature of the activity, and applicable U.S. regulations.
Shipping, hand-carrying, or electronically transferring research assets to a sanctioned or embargoed country may be subject to sanctions and export control requirements.
Research assets may include:
- Research equipment and instruments
- Chemicals, biological materials, and research samples
- Software and source code
- Technology and technical information
- Research data
- Engineering drawings or technical specifications
- Other research materials or information
ORS can assist in determining whether a proposed transfer requires additional review or U.S. government authorization.
Sanctions may restrict financial transactions, purchases, payments, agreements, and other University activities involving certain countries, organizations, or individuals.
Researchers should contact ORS before:
- Purchasing goods or services involving a sanctioned or embargoed country.
- Making payments or providing compensation to individuals or organizations in a sanctioned or embargoed country.
- Accepting funding or other support involving a sanctioned organization.
- Entering into a research agreement, collaboration agreement, or other University agreement involving a sanctioned or embargoed country.
ORS will coordinate with the appropriate University offices, as needed.
Activities involving sanctioned countries may require screening of participating organizations and individuals against applicable U.S. government restricted party lists.
ORS conducts Restricted Entity Screening, when appropriate, to identify applicable restrictions and determine whether additional review or U.S. government authorization may be required before an activity proceeds.
Research activities involving sanctioned or embargoed countries may also be subject to federal sponsor requirements, research agreements, University policies, or other institutional requirements.
These requirements may affect:
- International collaborations
- Research locations
- Participation by foreign organizations or individuals
- Research information sharing
- International travel
- Financial transactions
- Research agreements
- Sponsor disclosure or approval requirements
ORS can assist researchers in identifying applicable research security and sponsor requirements and coordinate with other University offices, as appropriate.
Country-Specific Activity Guidance
ORS has developed country-specific activity guidance for sanctions programs that commonly affect University research activities.
| Country | Description |
|---|---|
| Cuba | Guidance for research, travel, collaborations, financial transactions, shipments, and other activities involving Cuba. |
| Iran | Guidance for research, travel, collaborations, services, financial transactions, and export controls involving Iran. |
| Russia | Guidance for research, travel, collaborations, export controls, and other activities involving Russia. |
Sanctions programs change over time. If you are planning an activity involving another country and are uncertain whether sanctions or export controls apply, contact ORS before proceeding.
Related Guidance
| Related Guidance | Description |
|---|---|
| International Travel | Guidance for international travel involving research, teaching, field work, conferences, or other University activities. |
| International Collaborations | Guidance for planning, establishing, conducting, and managing research collaborations with international researchers, institutions, companies, and organizations. |
| International Transfers (Shipments, Hand-Carry & Electronic Transmissions) | Guidance for shipping, mailing, hand-carrying, or electronically transferring research equipment, materials, software, technology, technical information, or research information internationally. |
| Sharing Research Information | Guidance for sharing research information, data, software, technology, technical information, presentations, publications, or other research outputs with collaborators, sponsors, companies, government agencies, or other third parties. |
| Restricted Entity Screening | Learn how organizations and individuals are screened against U.S. government restricted party and entity lists before certain University activities. |
| Export Control Classification | Learn how equipment, materials, software, technology, and technical information are classified under U.S. export control regulations. |
| Countries of Concern | Learn about countries that may require additional review because of export control regulations, federal research security requirements, sponsor expectations, or institutional policy. |
| Office of Foreign Assets Control (OFAC) | Learn about U.S. sanctions programs, embargoes, and restrictions affecting countries, organizations, and individuals. |
Frequently Asked Questions
Do all activities involving sanctioned or embargoed countries require ORS review?
Not necessarily. Requirements depend on the country, participating organizations or individuals, proposed activity, and applicable U.S. regulations. Researchers should contact ORS before proceeding whenever they are uncertain whether sanctions or export control requirements apply.
Can I travel to a sanctioned or embargoed country for University research?
Possibly. Depending on the country and proposed activities, travel may require additional review or prior U.S. Government authorization. Contact ORS before making University-related travel arrangements to a sanctioned or embargoed country.
Can I collaborate with researchers in sanctioned countries?
Possibly. Research collaborations involving sanctioned countries may be subject to U.S. sanctions, export control regulations, sponsor requirements, and other institutional requirements.
ORS can review the proposed activity to determine whether additional requirements apply and whether the activity may proceed.
Do sanctions apply to virtual meetings and online collaborations?
They may. Certain services, technical assistance, research activities, or transfers of research information conducted electronically may be subject to U.S. sanctions or export control regulations.
Can I share research information with someone in a sanctioned country?
Possibly. Requirements depend on the country, recipient, information being shared, nature of the activity, and applicable U.S. regulations.
Contact ORS before sharing research information, software, source code, technology, or technical information with individuals or organizations in sanctioned or embargoed countries whenever you are uncertain whether restrictions apply.
Are Countries of Concern the same as sanctioned or embargoed countries?
No. Countries of Concern are identified under research security or sponsor-specific frameworks and are not necessarily subject to U.S. economic sanctions or trade embargoes.
Different requirements may apply depending on the country and proposed research activity.
Need Assistance?
Activities involving sanctioned countries frequently involve overlapping sanctions, export control, research security, sponsor, financial, and institutional requirements.
Contact the Office of Research Security before making travel arrangements, entering into agreements, transferring research information or materials, providing services, or beginning research activities involving a sanctioned country.
Early consultation helps identify applicable requirements, determine whether U.S. Government authorization is required, and support compliant international research and collaboration.