Economic Sanctions and Embargoes

Certain countries, industries, entities and individuals are subject to sanctions administered and enforced by the Office of Foreign Assets Control (OFAC). These sanctions may restrict your ability engage in a project, collaboration or other transaction with that country, industry, entity or individual.  OFAC restrictions and licensing requirements may apply to data, software and information, in addition to physical items.  The EAR and ITAR also have certain country-based prohibitions.

View this pdf for OFAC Sanctioned Countries

Details concerning the sanctions program for each of these countries can be found on OFAC’s website.

Targeted Sanctions Against Individuals, Entities or Industries

OFAC sanctions also prohibit transactions with or activities involving certain individuals, entities and industries without government authorization, no matter where in the world they are located.  You can search whether an individual, entity or industry is on OFAC’s Specially Designated Nationals and Blocked Persons list (SDN List), as well as other sanctions lists, on the OFAC website.

Consequences of Non-Compliance

Failure to comply with U.S. sanctions regulations may result in significant civil and criminal penalties.  Civil penalties can include fines ranging up to $1,075,000 for each violation.  Criminal penalties for willful violations can include fines ranging up to $20 million and imprisonment of up to 30 years. 

ITAR and EAR Prohibitions

The ITAR prohibit the export of defense articles and defense services, including technical data, to/from certain countries in certain (and in some cases, practically all) circumstances.  More information is available here.

Under the EAR, the Bureau of Industry and Security implements certain sanctions against Cuba, Iran, North Korea, Sudan and Syria.  In addition, some countries are subject to special license requirements and policies under the EAR.  More information is available here.