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Embargoed, Sanctioned, or Prohibited Destinations, Organizations, or Individuals

Ask before Acting

Any activity involving an embargoed, sanctioned, or prohibited country, destination, organization, or individual generally poses significant risk and must be approved by the export control office in advance of initiation of the activity.

Foreign Countries of Concern

The CHIPS and Science Act of 2022 identifies China, North Korea, Russia, and Iran as countries of concern for foreign interactions.

Risks faced by academia from China according to the FBI (PDF) and steps that can be taken to protect from counterintelligence threats

Exemptions and Approval Requirements

Based on specific exceptions in the export control regulations, many university activities are effectively pre-approved and do not require approval from the export control office when interacting with foreign persons. In general, this exemption includes non-scientific, non-technical, and non-engineering activities. Activities exempt from approval by the export control office include:

  • Teaching of registered classes in the academic catalog so long as the technical nature does not go beyond general scientific, mathematical or engineering principles commonly taught in schools, colleges and universities;
  • Non-science, non-technical, and non-engineering faculty carrying-out non-science, non-technical, and non-engineering research on-campus so long as: software is not being used by a foreign person, goods are not being transferred to a foreign person, and the research is intended to be published openly with broad distribution; and
  • Conference presentations and conference dialogue open to the public in a non-embargoed, non-sanctioned, and non-prohibited country without a particular substantial interaction when discussing only information that lawfully exists in the public domain.

Activities involving highly regulated destinations, organizations, and individuals that require approval include exports from any country, purchasing, software distribution, software development, research collaborations, proprietary work for others, sharing product specifications, item transfers, item shipments, international handcarry of items, hiring a foreign person, hosting foreign visitors, working with research students who are foreign persons, release of information, presentations, speaking engagements, electronic communications, facility tours, or the like. Any ambiguity should be resolved by asking before acting.

Embargoed, Sanctioned, or Prohibited Countries or Destinations

The applicable destination-based regulations can change frequently. The EAR identifies embargoed countries and foreign persons. OFAC identifies sanctioned countries and foreign persons. The ITAR identifies embargoed countries and foreign persons. DOE and NRC also identify countries and foreign persons that require licensing. Various prohibited or restricted party lists also exist (e.g., Denied Parties List, Entity List, Unverified List, Debarred List, Munitions E.C. Order, Specially Designated Nationals and Blocked Persons List).

List of High-Risk Countries from Northeastern University.