U.S. Economic Sanctions: University of California’s OFAC Compliance Initiatives

In the international academic community, the Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury is a key player in implementing economic and trade sanctions. These sanctions affect the University of California (UC) due to their broad reach towards certain countries, individuals, and entities.

Impact of OFAC Sanctions on UC

OFAC oversees sanctions programs against various countries, including but not limited to:

• Cuba
• Iran
• North Korea
• Syria
• Specific regions of Ukraine (Crimea, Donetsk, and Luhansk)

You can find the most recent list of sanctions and related information on the OFAC website: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/Programs.aspx

UC academic collaborations with foreign institutions and organizations usually do not necessitate export licenses, unless they involve restricted research, services, entities, or sanctioned countries. Determine if export licenses are needed and always verify if the foreign individual and/or organization are not blocked or sanctioned.

Activities Requiring Export Control Officer Guidance

If engaging in any of the following activities involving a comprehensively sanctioned country, listed individual, or entity, consult your Export Control Officer:

1. Imports/exports of research samples, artwork, or any research material
2. Collaboration with individuals residing in a sanctioned country
3. Research in, or travel to conferences in, the specific countries
4. Transfer of funds to

Stay informed as OFAC regulations frequently change, and non-compliance can lead to penalties and delays in research. Contact your Export Control Officer for the most recent guidance.

Licensing, Timelines, and Applicable Parties

• Licensing Timelines: Compliance timelines can take up to three months or more.
• Applicable Parties: OFAC regulations apply to all U.S. persons, which includes U.S. citizens, legal permanent residents, green card holders, and any entity organized under U.S. laws, regardless of their location.

Exempt Transactions and Exceptions

Exempt transactions, such as export or import of information and informational materials, and exceptions like peer review activities, should be considered when planning international activities. Contact your Export Control Officer to help determine if an exemption or exception applies to your planned activities.

Record Keeping and UC Compliance Resources

OFAC regulations require record-keeping. Ensure compliance by consulting the UC Records Retention Schedule: https://recordsretention.ucop.edu/index.php/du/retentionSchedules/recordCategory

Stay Informed with UC Compliance Alerts

Review UC’s compliance alerts to stay updated:

• Federal Laws May Regulate Research/Telework from Certain Countries (pdf)
• Federal Laws May Regulate Whether You Can Provide Online Classes to Students Located outside the United States (pdf)
• Updated Sanctions on Russia, Belarus, and Specific Regions of Ukraine (pdf)

By staying informed and collaborating with your Export Control Officer, the UC community can maintain compliance with OFAC sanctions and continue to build valuable international collaborations.