Sanctions & Embargoes
Sanctions & Embargoes
The U.S. Treasury Department's Office of Foreign Assets Control (OFAC) administers a number of different sanction and embargo programs. OFAC administers U.S. sanctions against Iran, Cuba, North Korea, Syria and various other countries. There are serious penalties for violations. In addition to the restrictions of OFAC, Florida Statute mandates that no state funds may be used to facilitate travel to a country listed as a state sponsor of terrorism by the US Department of State.
Sanction Types
Sanctions can be either comprehensive or selective, using the blocking of assets and trade restrictions to accomplish foreign policy and national security goals.
Comprehensive Sanctions: Generally prohibits all direct or indirect imports/exports, trade brokering, financing, or facilitating against most goods, technology, and services. Transactions will require a specific license or an approved exception before the transaction can take place.
Limited Sanctions: Block specific practices, such as diamond trading. Most research and business activities may be conducted without an OFAC special license, so long as specific criteria are met as outlined in the regulations for a General License.
Regime or List Based Sanctions: Blocks specific property of targeted foreign governments, regimes, supporters, and persons that are not necessarily country-specific, but which may be owned, controlled by, or acting for or on behalf of, targeted countries or entities as a front organization. Collectively, such targeted individuals and entities are called "Specially Designated Nationals."
prohibited transactions
Prohibited transactions are trade or financial transactions and other dealings in which U.S. persons may not engage unless authorized by OFAC or expressly exempted by statute. Because each program is based on different foreign policy and national security goals, prohibitions may vary between programs. Prohibited transactions with sanctioned countries include:
- Exportation, importation, or provision of services, including research and educational
services may be prohibited
- Provision of financial services or transactions involving a blocked entity, blocked person or comprehensively sanctioned country are prohibited.
In some cases, OFAC may provide general licenses authorizing the performance of certain categories of transactions. OFAC also issues specific licenses on a case-by-case basis under certain limited situations and conditions.
It is important to contact the USF Office of Export Controls if you are working with a person or entity in a country with OFAC sanctions. These countries are deemed countries of concern by USF and require review.
Prohibited Services
- Advising a student on a dissertation or thesis when the student is located in a comprehensively
sanctioned country.
- Providing educational services in the form of distance learning, class instruction,
grading, and return of coursework or exams, research advising, or exchange of unpublished
course information. This would include examples including activities such as: allowing
an individual located in Iran access to group research meetings via Skype; or allowing
a student to submit course assignments for grading from Iran.
- Provision of business services such as USF email, CANVAS, Remote Desktop Gateway (RDG)
or other internet-based services requiring a USF NETID to access.
- Provision of educational services related to research, such as accepting data or samples
from a comprehensively sanctioned country, providing analysis of those samples and
returning the data set.
- Importing research samples or datasets from a comprehensively sanctioned country,
even if there is not a monetary value to the samples. For example, if a professor
travels to Cuba under the auspices of a general licenses to conduct research in Cuba,
the professor would not be allowed to collect and import research samples back to
the United States without a specific license from OFAC.
- Provision of financial services to an individual in a sanctioned country or in a third country without a valid visa. This would include payment for services such as teaching or research, even if the payment went to a US bank account.
correspondence via telecommunication or mail
Correspondence via telecommunication or mail with individuals in sanctioned countries is authorized under certain instances, such as:
If a person physically located in a sanctioned country contacts me to discuss my research,
can I share information with them?
It is acceptable to share pre-created information that is in the public domain. Feel
free to send a copy of your CV or a link to your open source website.
A student has applied from a sanctioned country. I would like to offer them a position
at USF as my graduate research student. Can I communicate this to them through a letter?
Yes. It is legal to correspond with individuals in sanctioned countries to exchange
public information or information related to a planned student visa.
Can I send a student in a sanctioned country the syllabus to my course, if they are
planning to attend the course on-campus in the United States?
You can send them a link to a website that does not require login where the syllabus
is posted. However, you are prohibited from providing educational guidance or requiring
the student submit assignments prior to their arrival in the United States.
LICenseS
A license is an authorization from OFAC to engage in a transaction that otherwise would be prohibited. There are two types of licenses: general licenses and specific licenses. A general license authorizes a particular type of transaction for a class of persons without the need to apply for a license. A specific license is a written document issued by OFAC to a particular person or entity, authorizing a particular transaction in response to a written license application.
Persons engaging in transactions pursuant to general or specific licenses must make sure that all conditions of the licenses are strictly observed. The USF Office of Export Controls is available to apply for specific licenses on behalf of USF when necessary.
Generally speaking, a license may be required to ship or transfer "controlled" technology, data, or items to certain countries outside of the United States (the technology, data, or items are considered to be "controlled" if found on the EAR Commerce Control List or the ITAR Munitions List). This includes the transfer of "controlled" technology, data, or items to foreign nationals within the U.S. (i.e., deemed export) or outside the U.S.
Please note: An item does not have to be military in nature to require a license. View OFACs complete listing of sanctions.
OFAC administered sanctions not only cover the export of goods, they also cover the export of services. For example, distance learning services may not be provided to Cuba, Iran, Sudan or Syria under the current OFAC sanctions without a license. See the University of South Florida's Distance Learning policy - 10-067 (PDF).
Keep in mind that foreign countries also have their own import regulations that must be followed.
Please contact the Office of Export Controls, 974-5638 or by email for detailed information regarding the restrictions and sanctions on the countries listed below and/or for an export control review of your collaborative or travel plans.
| International Traffic in Arms Regulations (ITAR) | Export Administration Regulations (EAR) | Office of Foreign Assets Control (OFAC) |
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*Indicates comprehensive sanctions