Export Controlled or Sanctioned Countries, Entities and Persons

Overview

Certain organizations and individuals are subject to trade sanctions, embargoes, and other restrictions under US law. These restrictions apply to both domestic and foreign transactions. Stanford's Restricted Party Screening tool will permit you to quickly check and document whether a person or an organization is a restricted party. If you intend to ship or transact with any person or organization that appears on a restricted list, immediately contact Stanford's Export Control Office.

In addition, certain countries are subject to either comprehensive sanctions or targeted sanctions. Comprehensive sanctions prohibit virtually ALL exports/imports and other transactions without a license or other US Government authorization. Targeted sanctions are prohibitions on trade in specified goods, technologies, and services with specific organizations (including foreign governments) and persons.

If you intend to travel on Stanford business to, ship or transact with any country that that is identified on the Comprehensively Sanctioned Country lists below, you MUST contact the VPDoR's Export Control Office for guidance ASAP per Stanford policy.  Because of the complex federal trade regulations governing these countries, as well as the severe civil and criminal penalties that could be levied for sanctions violations, faculty, staff and students should not attempt to interpret export licensing requirements or license exclusions for travel to or transactions with comprehensively sanctioned countries (Cuba, Iran, Syria, North Korea and the Crimea Region of the Ukraine) on their own.

If you intend to ship or transact with any other country that is identified on the Targeted Sanctions Country lists below, please use the Stanford Export Controls Decision Tree and conduct a Restricted Party Screen.  Given the numerous dual use export controls and Targeted Sanctions on Iraq, you should contact the Export Control Office before engaging in activity with persons or organizations in that country.

Countries

Comprehensively Sanctioned Countries and Regions

Office of Foreign Assets Control Regulations - OFAC

Crimea and so-called Donetsk People's Republic and Luhansk People's Republic Regions of Ukraine, Cuba, Iran, North Korea, Syria 

Export Administration Regulations - EAR

Crimea and so-called Donetsk People's Republic and Luhansk People's Republic Regions of Ukraine, Cuba, Iran, North Korea, Syria 

See Sanctions Program and Country Summaries and the EAR's Part 746 embargoes pages for more specific information.

Targeted Sanctions Countries 

Office of Foreign Assets Control Regulations - OFAC

Burundi, Central African Republic, Democratic Republic of the Congo, Libya, Lebanon, Sudan, South Sudan, Somalia, Belarus, Iraq, Yemen, Myanmar (formerly Burma), Russia/Ukraine, Zimbabwe, Balkans, Venezuela

Export Administration Regulations - EAR

Iraq

See Sanctions Program and Country Summaries and the EAR's Part 746 embargoes pages for more specific information.

Countries with Restricted Parties on the EAR Entity List 

China, Canada, Germany, Iran, India, Israel, Pakistan, Russia, Egypt, Malaysia, Hong Kong, Kuwait, Lebanon, Singapore, South Korea, Syria, Ukraine, United Arab Emirates the United Kingdom.

International Traffic in Arms Regulations - ITAR Prohibited Countries

Afghanistan, Belarus, Central African Republic, Cuba, Cyprus, Eritrea, Fiji, Iran, Iraq, Cote d'Ivoire, Lebanon, Libya, North Korea, Syria, Vietnam, Myanmar, China, Haiti, Liberia, Rwanda, Somalia, Sri Lanka, Republic of the Sudan (Northern Sudan), Yemen, Zimbabwe, Venezuela, Democratic Republic of the Congo.

Persons and Organizations

There are a number of important lists that address trade sanctioned persons and organizations:

1. The Specially Designated Nationals and Blocked Persons List (Treasury);
2. The Foreign Sanctions Evaders List (Treasury);
3. The Entity List (Commerce);
4. The Denied Persons List (Commerce);
5. The Unverified List (Commerce);
6. The Nonproliferation Sanctions List (State);
7. The AECA Debarred List (State).

Stanford's Restricted Party Screening tool includes each of these lists and should be used to identify U.S. Government sanctioned persons and organizations.

A Note About Anti-Bribery Laws

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), a person 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 to further business activities.  

Many geographic regions include countries with a high incidence of requests for improper payments to facilitate a transaction.  High risk regions include most countries in Africa and the Middle East, a majority of countries in Asia, including China and India, Eastern Europe and Russia. The Transparency International website, which contains country specific information about corruption risks, and Stanford’s anti-bribery policy, are excellent informational resources.

Violations of these laws can result in significant criminal penalties, 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, retained to assist with shipments or interactions with customs officials.

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, exported goods that have been held up at ports of entry.   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.

If you are a member of the Stanford community and still have questions, Stanford's Export Control Office can provide immediate assistance.