Office of Foreign Assets Control (OFAC)

Guidance on Research Activities in Iran

Sanctions and Export Control Restrictions for Entities and Individuals

Under U.S. sanctions laws and export control regulations, certain entities and individuals (both foreign and domestic) may be subject to trade sanctions, embargoes, and other restrictions on exports, re-exports, or transfers of U.S.-origin items.  In addition, certain countries may be subject to either comprehensive or targeted sanctions or export restrictions.

  • Comprehensive sanctions prohibit nearly all exports and other business transactions without specific government authorization. (e.g., Cuba, Iran, North Korea).
  • Targeted sanctions prohibit transactions related to specific goods, technologies, and services with specific sanctioned entities or individuals, or apply to certain industries or sectors of a country’s economy (e.g., the financial services, energy, mining, and defense and related material sectors of the Russian economy).

If you are unclear whether a transaction with a particular entity or individual may be subject to restrictions, please consult with the USC Office of Culture, Ethics and Compliance, who maintains a screening tool allowing for prompt identification of any sanctions or export controls that may apply.

Who Must Comply?

All “U.S. Persons” are required to comply with the sanctions.  For purposes of these sanctions programs, the term “U.S. Persons” in most cases means (i) U.S. citizens; (ii) U.S. permanent residents; (iii) entities incorporated in the U.S. and their foreign branch offices; and (iv) persons physically located in the U.S.

Even wholly non-U.S. Persons must also be aware of and confirm compliance with U.S. economic sanctions programs because the U.S. Government applies and enforces many aspects of its sanctions programs extraterritorial.  For example, these sanctions programs can be triggered if a transaction that otherwise takes place outside of the United States involves: (i) participation, approval or facilitation by individual U.S. Persons (e.g., as senior executive or board member); (ii) goods subject to U.S. law; or (iii) U.S. dollar-denominated transactions.

Comprehensively Sanctioned Countries

U.S. Department of the Treasury Office of Foreign Assets Control (OFAC) maintains comprehensive economic sanctions programs that prohibit U.S. Persons from engaging in virtually all trade and financial transactions involving the following countries and regions:

  • Cuba
  • Iran
  • Crimea Region of Ukraine
  • North Korea
  • Syria

In addition to the sanctions regulations administered by OFAC, the U.S. government maintains separate and overlapping export control regulations that prohibit virtually all exports and re-exports of U.S.-origin items (goods, software, and technology) to these comprehensively sanctioned countries/regions.

Limited Sanctions Programs

OFAC maintains more limited sanctions against a number of additional countries where sanctions may apply depending on entity/individual/organization/item/ or industry (i.e., sectoral sanctions). These countries are:

  • Belarus
  • Burundi
  • Central African Republic
  • Democratic Republic of Congo
  • Iraq
  • Lebanon
  • Libya
  • Mali
  • Nicaragua
  • Russia
  • Somalia
  • South Sudan
  • Ukraine
  • Venezuela
  • Yemen
  • Zimbabwe

Restricted Parties Lists

In addition to countries, the U.S. government also maintains certain sanctions and other trade restrictions against lists of individuals, entities, and organizations that have violated U.S. export control laws, have participated in proliferation activities, or have been determined to be terrorists, terrorist organizations affiliated with certain sanctioned governments, and for other reasons.  These lists are collectively known as “Restricted Parties Lists.”  The most significant of these are OFAC’s lists of sanctioned entities and individuals, including the Specially Designated Nationals and Blocked Persons (SDN) List, Foreign Sanctions Evaders (FSE) List, and the Sectoral Sanctions Identification (SSI) List.

U.S. “Secondary” Sanctions

In addition, the U.S. government implements “secondary” sanctions, which specifically are intended to broaden the reach of U.S. sanctions programs extraterritorially to impact foreign persons that provide material support to certain sanctioned countries, entities and individuals.  These secondary sanctions vary widely by sanctions program and activity.

Arms Embargoes for Defense Articles, Technical Data, and Defense Services

The U.S. Department of State Directorate of Defense Trade Controls (DDTC) administers the International Traffic in Arms Regulations (ITAR).  The ITAR regulate the export, re-export, transfer, temporary import and brokering of defense articles, as well as technical data and defense services classified on the U.S. Munitions List (USML).  DDTC maintains arms embargoes for ITAR items against certain foreign countries (Proscribed Countries).

The Proscribed Countries are:

  • Afghanistan
  • Belarus
  • Burma (Myanmar)
  • Central African Republic
  • China*
  • Cuba
  • Cyprus
  • Democratic Republic of Congo
  • Eritrea
  • Haiti
  • Iran
  • Iraq
  • Lebanon
  • Libya
  • North Korea
  • Somalia
  • South Sudan
  • Sudan
  • Syria
  • Venezuela
  • Zimbabwe

*Note: Current U.S. national security policy is to deny licenses and other approval for any ITAR-controlled exports, reexports, or transfers to (and imports from) China of defense articles, defense services, and technical data.  It is prohibited to obtain an export license from DDTC for the export of U.S. defense articles, defense services, or technical data to China.

Other Agencies and Regulations

There are various export controls and sanctions laws and regulations that may be enacted by Congress or might implicate companies in other regulated areas.  For example, the Department of Energy and the Nuclear Regulatory Commission regulate, among other things, the transfer of nuclear-related U.S. technology between companies, countries, and individuals.  In addition, Congress has separate authority to pass laws that could impose an export control or sanctions restriction separate from existing statutory authorities.