Export Controls Decision Tree: UN Arms Embargoed Countries

Is the disclosure⁽¹⁾ of technology, shipment⁽²⁾, hand carry, transmission, or transfer, to include laptops, tablets, smart phones and other digital devices, a) to an entity or person in the UN arms embargoed countries of North Korea or Iraq, b) to one of the following countries identified by the US Department of State as a "State Sponsor of Terrorism" (Iran, Syria, Cuba) or the Crimean or so-called Donetsk or Luhansk People's Republic (DNR/LNR) Regions of the Ukraine, or c) to a national of Iran, Syria, Cuba, North Korea, or Crimea/DNR/LNR and "ordinarily resident" in those countries or regions yet working or studying remotely outside the US on an expired US visa?

YES           NO

⁽¹⁾ Under US export control regulations, "disclosure" includes both oral and visual disclosure.

⁽²⁾ The U.S., the United Kingdom, and many other countries have strict criminal laws governing interactions with government officials, including customs officials.  Under the U.S. Foreign Corrupt Practices Act (FCPA), you may not offer or pay anything of value (this not only includes cash, but can include gifts, entertainment or other favors) to a foreign government official in order to gain an improper advantage or obtain retain or further business activities.  Enforcement actions in recent years have included many cases where customs officials have requested or received bribes in exchange for agreeing not to inspect, or to release, goods that have been held up.

Violations of these laws can result in significant criminal penalties for both you and Stanford, including fines and potential jail time.  Stanford is forbidden under the FCPA from paying a fine on behalf of an employee, so any resulting financial penalty incurred by a Stanford employee in the course of their work is a personal responsibility.  

Individuals can be held responsible for the actions of a 3rd party, such as a logistics provider or customs broker, whom you retain to assist with shipments or interactions with customs officials.  If you are traveling and know you will need materials on site when you arrive, to avoid being pressured to make improper payments, you should arrange to ship them ahead using Stanford's preferred carrier, JAS Forwarding USA (650-581-7230, US-StanfordU@jas.com), in Burlingame, CA.