Sanctions & Embargoes

Syria

The U.S. Department of Treasury, Office of Foreign Asset Controls (OFAC) administers U.S. sanctions against Syria and other countries. There are serious penalties for violations. The University has a strong commitment to its academic mission, which must be balanced with 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 Syria.

This guidance is intended to provide faculty with a framework for lawful and unlawful activities when a citizen of Syria (including dual citizens of Syria and another country) is in one of three travel categories, as follows:

  1. Syrian person is temporarily traveling outside the United States, but holds a valid U.S. visa with currently-valid authorization to enter the United States;
  2. Syrian person located in a country other than Syria, outside the United States, with no currently-valid authorization to enter the United States;
  3. Syrian person located in Syria either temporarily or indefinitely with or without a valid U.S. entry.

Activities and Applicable Laws

1) Educational activities with students in the United States

STATUS: Always permitted

APPLICABLE LAW
While a student is within the territory of the United States on a valid visa (including F and J visas) U.S. persons are authorized to take any actions necessary to give effect to the activity authorized by the visa. This authorization includes permission to provide teaching and academic advice, preparing, defending, or advising on a dissertation or academic thesis, research activities, and other educational services. This authorization also includes permission to conduct financial transactions necessary to give effect to the activity authorized by the visa.

2) Activities related to publishing and marketing 

STATUS: Always permitted

APPLICABLE LAW
Even if an academic colleague who is a Syrian citizen is outside the United States, U.S. persons are authorized to engage in transactions necessary and ordinarily incident to the publishing and marketing of manuscripts, books, journals and newspapers. This includes collaborating on the creation and enhancement of written publications, and substantive editing of written publications. This authorization includes permission to conduct such activities even when one party is physically located in Syria.

OFAC has indicated that it does not consider a dissertation or academic thesis to be a published work under this authorization. Therefore, this authorization does not apply to activities by U.S. persons that benefit Syrian persons in connection with preparing, defending, or advising on a dissertation or academic thesis. However, Syrian persons may continue these activities independently outside the United States. U.S. persons are permitted to receive information regarding the Syrian persons' progress.

3) Export and import of informational materials

STATUS: Always permitted

APPLICABLE LAW
Even if a Syrian colleague is outside the United States, U.S. persons are generally authorized to exchange with such colleague any unaltered information and informational materials, whether commercial or otherwise, regardless of format or medium of transmission. "Information and informational materials" includes publications, films, posters, phonograph records, photographs, microfilms, microfiche, tapes, compact disks, CD ROMs, artworks, and news wire feeds.

This authorization does not apply to materials not fully created and in existence at the date of the transaction nor does it apply to the export of software or technology subject to export controls.

4) Personal communications

STATUS: Always permitted

APPLICABLE LAW
Even if a Syrian citizen colleague is outside the United States, U.S. persons are authorized to send and receive personal communications, which do not involve the transfer of anything of value or the provision of a service.

5) Import of services from Syria

STATUS: Always permitted

APPLICABLE LAW
Even if a Syrian citizen is traveling outside the United States or is located in Syria, with or without a valid U.S. visa or currently-valid authorization to enter the United States, U.S. persons are authorized to import services from Syria and/or provided by Syrian citizens. That means that Syrian persons outside the United States or in Syria may provide academic services such as teaching, advising, supervising research, conducting research, or independently work on a dissertation that is ultimately reviewed by U.S. persons.

6) Financial transactions

STATUS: Permitted in certain circumstances

APPLICABLE LAW
U.S. persons are permitted to transfer funds to Syrian citizens' bank accounts in the United States if the Syrian person is in the United States on a valid visa, or is outside the United States with a valid U.S. visa and a currently-valid U.S. entry authorization (travel category 1).

If a Syrian person is outside the United States (in a third country, i.e., travel category 2) or in Syria (i.e., travel category 3) with no currently-valid authorization to enter the United States, then U.S. persons should suspend payments that would benefit the Syrian person until that person is authorized to return to the United States.

7) Export of services to Syrian persons outside the United States

STATUS: Permitted in certain circumstances

APPLICABLE LAW
You may provide academic services such as teaching, advising, supervising research or providing distance education to a Syrian person who is traveling outside the United States and has a valid U.S. visa with a currently-valid authorization to enter the United States (travel category 1).

U.S. persons are generally prohibited from exporting services, directly or indirectly, from the United States or elsewhere, where the benefit of such services is received in Syria. Under this prohibition, you may not provide academic services such as teaching, advising, supervising research or providing distance education where the benefit of those services is received directly or indirectly in Syria.

If the Syrian person is in a third country (travel category 2), the prohibition applies if the benefit of your services is received directly or indirectly in Syria. You should seek legal advice for these circumstances.

8) Export of Services

STATUS: Prohibited

APPLICABLE LAW
U.S. persons are generally prohibited from exporting services, directly or indirectly, from the United States or elsewhere, to Syria. Under this prohibition, you may not provide academic services such as teaching, advising, supervising research or providing distance education to a Syrian person who is in Syria (travel category 3) with no currently-valid authorization to enter the United States (travel category 3) unless that activity is a publishing activity, transaction in information or informational materials, or purely personal communication.

9) Transactions with Specifically Designated Nationals (SDNs)

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 Syria. Those individuals and entities are subject to an asset freeze. In addition, several individuals and entities from Syria are subject to a travel ban pursuant to designation on the SDN List.

In addition to the comprehensive sanctions on Syria, the Departments of State and Commerce impose strict export control restrictions on Syria. 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.