The U.S. Office of Foreign Assets Control (OFAC) limits what activities U.S. citizens and residents are allowed to participate in with individuals of certain foreign countries. These limitations are dependent upon the country in question and the activities being performed. For some countries, such as Iran, these limitations include not only conducting activities within the foreign country, but also include conducting activities with individuals from those countries, even if the individual is located outside of the country in question at the time of the activity.

Types of Sanctions and Affected Countries

Countries are categorized into groups based upon the limitations imposed by the sanctions.

1. Comprehensive Sanctions: In general, nearly ALL interactions and activities are prohibited without an export control license for these countries.  Note that some of the restricted activities can even apply to individuals who are "ordinarily resident" in these countries, even if they are not currently in the country in question at the time of the activity.

    Countries: Certain regions within Ukraine (Crimea, Donetsk, and Luhansk), Cuba, Iran, North Korea, Syria

 

2. Limited and Regime/List-Based Sanctions: Some interactions and activities related to these countries are prohibited without an export control license and/or the sanctions are targeted against specific individuals identified by the Treasury Department (referred to as Specially Designated Nationals [SDNs]) or against specific groups of people usually associated with a governmental body or regime.

 

The following is on overview of OFAC-sanctioned countries and the restrictions on certain activities. Additional information is available for some countries below.

• Balkans Region (includes Bosnia-Herzegovina, Macedonia/North Macedonia, Serbia, Kosovo region): Restrictions on activities with specific parties

• Belarus: Restrictions on activities with specific parties *Warning: These sanctions are rapidly changing--consult with ORCI*

• Burundi: Restrictions on activities with specific parties

• Central African Republic: Restrictions on activities with specific parties.

• Congo, Democratic Republic of: Restrictions on activities with specific parties

• Cuba: Restrictions on imports, exports, financial transactions, and travel

• Iran: Restrictions on imports, exports, and financial transactions

• Iraq: Restrictions on activities with specific parties

• Lebanon: Restrictions on activities with specific parties

• Libya: Restrictions on activities with specific parties

• Mali: Restrictions on activities with specific parties

• Nicaragua: Restrictions on activities with specific parties

• North Korea: Restrictions on imports, exports, and travel

• Russia/certain regions in Ukraine (Crimea, Donetsk and Luhansk): Restrictions on imports and exports, investment in the region, activities with financial/energy sectors *Warning: These sanctions are rapidly changing--consult with ORCI*

• Somalia: Restrictions on activities with specific parties

• South Sudan: Restrictions on activities with specific parties

• Syria: Restrictions on imports, exports, and financial transactions

• Venezuela: Restrictions on activities with specific parties

• Yemen: Restrictions on activities with specific parties

• Zimbabwe: Restrictions on activities with specific parties

 

If you are planning to conduct any work with countries subject to import, export, or travel restrictions, you must consult with the ORCI to discuss your specific situation (616-331-3197; [email protected]).

 

If you are working with individuals from countries subject to restrictions with specific parties, you are encouraged to contact the ORCI with the names of all individuals and entities involved. The ORCI can screen the individuals and entities against lists of restricted parties to ensure compliance with the regulations.

Penalties

The penalties for engaging in restricted activities without the proper export control license can be severe, and individuals can be held personally liable. Both individuals and the University can face criminal and civil penalties if export control violations occur.

Contact Us

If you are engaging in any GVSU-related work indicated below, please consult with the ORCI to discuss your specific situation to determine if an export control license is required (616-331-3197; [email protected]):

• Travel to an OFAC-sanctioned country
• Activities with individuals in OFAC-sanctioned countries
• Activities with individuals "ordinarily resident" in an OFAC-sanctioned country under comprehensive sanctions (i.e., certain region within Ukraine [Crimea, Donetsk, and Luhansk], Cuba, Iran, North Korea, Syria).