Sanctions & Embargoes

Libya, Somalia, Sudan and Yemen

The U.S. government does not currently maintain comprehensive sanctions against Libya, Somalia, Sudan, and Yemen; however, certain limited restrictions apply, administered by the U.S. Department of Treasury, Office of Foreign Asset Controls (OFAC). There are serious penalties for violations. The University has a strong commitment to its academic mission, which must be balanced against the obligation to comply with U.S. law. This guide outlines activities that can be lawfully conducted in the context of academic collaboration with citizens of Libya, Somalia, Sudan, and Yemen.

This guidance is intended to provide faculty with a framework for lawful and unlawful activities when a citizen of Libya, Somalia, Sudan, or Yemen (including dual-citizens) is in one of three travel categories, as follows:

  • Libyan, Somalian, Sudanese, or Yemeni person is temporarily traveling outside the United States, but holds a valid U.S. visa with currently-valid authorization to enter the United States;

  • Libyan, Somalian, Sudanese, or Yemeni person located in a country other than Libya, Somalia, Sudan, or Yemen, outside the United States, with no currently-valid authorization to enter the United States;

  • Libyan, Somalian, Sudanese, or Yemeni person located in Libya, Somalia, Sudan, or Yemen either temporarily or indefinitely with or without a valid U.S. entry.

Activities and Applicable Laws

1) All educational services and activities with students

STATUS: Always permitted

APPLICABLE LAW
The University is not prohibited from conducting any educational services and activities with students in any of the three travel categories who are citizens from Libya, Somalia, Sudan, and Yemen. You may provide all academic services, including teaching and academic advice, preparing, defending, or advising on a dissertation or academic thesis, research activities, and other educational services. You are always permitted to engage in publishing and marketing of manuscripts, books, journals, newspapers, and other written materials; collaborating on the creation and enhancement of written publications; substantive editing of written publications; sending and receiving related communications; and financial transactions related to such activities.

2)  Transactions with Specially Designated Nationals (SDLs)

STATUS: Prohibited

APPLICABLE LAW
The University must screen transactions for the involvement of Specially Designated Nationals (SDNs). OFAC's SDN List designates several individuals and entities from Libya, Somalia, Sudan, and Yemen. Those individuals and entities are subject to an asset freeze. In addition, several individuals and entities from Libya are subject to a travel ban pursuant to designation on the SDN List.

While there are no comprehensive sanctions against Libya, Somalia, Sudan, or Yemen, certain export controls apply to the export of technology and technical information, software, and commodities. The Departments of State and Commerce impose export control restrictions on Libya, Somalia, Sudan, and Yemen. The Department of Commerce, Bureau of Industry (BIS) restricts certain exports for reasons relating to chemical and biological weapons, nuclear proliferation, national security, missile tech, regional stability, and crime control. When exporting information or commodities that may be controlled, the University should analyze whether such exports are exempt (for example, due to the fundamental research exemption) or whether authorization from the State Department or Commerce Department must be secured.