Foreign Activity Operations Guide

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 generally aimed at prohibiting only certain activities with or within a country and may not restrict academic activities. OFAC may impose both criminal and civil penalties against individuals and institutions found to violate these sanctions.

As of May 2009, the following countries are subject to OFAC Countries Sanctions Programs: Balkans, Belarus, Burma, Cote D'Ivoire, Cuba, Democratic Republic of Congo, Iran, Iraq, North Korea, Sudan, Syria, and Zimbabwe. Iran, Cuba, Sudan and Burma 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 University Export Control Officer performs 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 and should be contacted in these circumstances. 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 OFAC web site. Should specific assistance be required, contact the University Export Control Officer, Office of the Dean of Research.