Foreign Activity Operations Guide

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Country Embargoes and Targeted Sanctions

The Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals against targeted foreign countries, terrorists, international narcotics traffickers, and those engaged in activities related to the proliferation of weapons of mass destruction. Economic sanctions maintained by the U.S. are generally known as "embargoes" and can be comprehensive bans or targeted sanctions. Conducting business of any kind, including academic activities with or within a country currently under a comprehensive embargo is greatly restricted and requires an OFAC license. Targeted sanctions are aimed more specifically at prohibiting certain activities with sanctioned persons or entities within a country and in most cases do not restrict academic activities. OFAC may impose both criminal and civil penalties against individuals and institutions found to violate these sanctions.

As of September 2013, the following countries are subject to OFAC Countries Sanctions Programs: Balkans, Belarus, Burma, Cote D´Ivoire, Cuba, Democratic Republic of Congo, Iran, Iraq, Lebanon, Libya, North Korea, Somalia, Sudan, Syria, Yemen, and Zimbabwe. Cuba, Iran, and Syria are presently subject to comprehensive economic sanctions. Targeted sanctions presently apply to the others.

The Specially Designated Nationals (SDN) List is updated regularly, and contains names of individuals and organizations that are restricted from "transactions or dealings" with U.S. individuals and entities. "Transactions or dealings" include any service, payment or agreement for a payment, regardless of the amount. The University screens all central payments made against the SDN list prior to their completion. The Office of the Vice Provost and Dean of Research (DoR) has created a Restricted Party Screening website for the Stanford community to perform SDN and related U.S. Government restricted party screens for foreign persons and organizations with whom Stanford is entering into an international research collaboration or agreement. Stanford individuals are expected to be aware of these requirements and to consider them when entering into transactions with or within a foreign country. For further information, consult the Stanford's Export Controlled or Embargoed Countries, Entities, and Persons web site.

Should specific assistance be required, contact the University Export Control Officer, Office of the Dean of Research (DoR).