Sanctioned Countries
The U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) maintains sanctions against certain countries, industries, entities and individuals. Certain countries are subject to comprehensive sanctions, while others are subject to targeted sanctions. Comprehensive sanctions prohibit transactions with a country’s government and virtually all other transactions, including exports/imports, involving the sanctioned country. Targeted sanctions prohibit transactions with specified industries, entities, or individuals listed on OFAC’s Specially Designated Nationals and Blocked Parties List or Consolidated Sanctions List. Dartmouth College and its personnel are prohibited from engaging in transactions with restricted parties without prior government authorization to do so.
Dartmouth Resources
Restricted Party Screenings: If you are dealing with a country subject to restrictions with specific parties, you are encouraged to contact the Director of the Office of Research Integrity and the Director of the Office of Sponsored Projects. Dartmouth has a license to a software program Visual Compliance which can be used to screen against lists of restricted parties to ensure compliance with sanctions regulations. If you are contemplating activities in countries subject to import, export, or travel restrictions, a license may be required.
OFAC Sanctioned Countries
Sanctions regulations vary significantly by country. These sanctions may require obtaining OFAC approval before conducting research or other activities in or involving the sanctioned country. Some sanctions are more restrictive than others, and apply to the whole country, while others are specifically target certain individuals or entities within a country. The list of sanctioned countries is updated periodically and is available here.
Comprehensive sanctions:
The Crimea, Donetsk (DNR) and Luhansk (LNR) Regions of Ukraine
Cuba
Iran
North Korea
Russia*
Syria
Venezuela
*Russia is subject to increasingly broad sanctions
NDAA Section 889 Telecommunications Prohibition:
Prohibition on Certain Chinese-origin Telecommunications Equipment or Services
Section 889 of the National Defense Authorization Act of 2019 prohibits federal agencies from entering into contracts, including sponsored research contracts, with an entity that uses “covered telecommunications equipment or services” as a “substantial or essential component of any system” or as “critical technology as part of any system”. Section 889 also prohibits the use of federal loan or grant funds to procure or obtain covered telecommunications equipment or services. These prohibitions went into effective on August 13, 2020.
Section 889 also prohibits contractors from providing to the Government any equipment, system, or service that uses covered telecommunications equipment or services as a substantial or essential component of any system, or as critical technology as part of any system. This prohibition went into effect on August 13, 2019.
“Covered telecommunications equipment or services” are:
- Telecommunications equipment produced by Huawei Technologies Company, ZTE Corporation, or any subsidiary or affiliate of these entities;
- Video surveillance technology and equipment used for certain public safety, physical surveillance, or national security purposes and produced by Hytera Communications Corporation, Hangzhou Hikvision Digital Technology Company, Dahua Technology Company, or any subsidiary or affiliate of these entities;
- Telecommunications or video surveillance services provided by any of the above-named entities or using the above-described equipment; and
- Telecommunications or video surveillance equipment or services of an entity that the U.S. Secretary of Defense reasonably believes to be owned or controlled by, or otherwise connected to, the government of the People’s Republic of China.