This page identifies countries, entities, and persons sanctioned or restricted by the US Federal Government because of concerns about US national and economic security. UT Dallas researchers must consider the sanction or export licensing status of the destination, recipient, or collaborator when preparing international shipments, transfers, or disclosures of items, materials, or technical data.

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. Certain countries are also 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 UT Dallas business to, ship or transact with any country that is identified on the Comprehensively Sanctioned Country lists below, you must contact the Export Control Office, (972) 883-4718 for guidance.  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 on their own.

If you intend to travel on UT Dallas business to, ship or transact with any country that is identified on the Targeted Sanctions Country lists below, or with a person or an organization identified as a restricted or sanctioned party, please contact the Export Control Office, (972) 883-4718 for guidance. UT Dallas has access to an export compliance screening tool that will permit the Export Control Office to verify whether a person or an organization is a restricted party, and identify if any licensing requirements or license exclusions are required for engaging with the individual or organization.

Countries

Comprehensively Sanctioned Countries

Crimea Region of Ukraine, Cuba, Iran, North Korea, Syria

Targeted Sanctions Countries

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

Countries subject to International Traffic in Arms Regulations Country Policies

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

Countries with Restricted Parties on the EAR Entity List 

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

See the OFAC Sanctions Program and Country Summaries, the ITAR Country Policies, and the EAR’s Part 746 embargoes pages for more specific information.

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).

UT Dallas’ export compliance screening tool includes each of these lists and should be used to identify U.S. Government sanctioned persons and organizations. Please contact the Export Control Office before engaging in a shipment, transfer, or disclosure of items, materials, or technical data with a person or organization subject to sanction or restriction by the US Government.

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 contains country specific information about corruption risks.

Violations of these laws can result in significant criminal penalties, including fines and potential jail time.  UT Dallas is forbidden under the FCPA from paying a fine on behalf of an employee, so any resulting financial penalty incurred by a UT Dallas 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 a preferred carrier.

If you are a member of the UT Dallas community and still have questions, UT Dallas’ Export Control Office can provide immediate assistance.

Acknowledgement:  Significant portions of this page’s text was taken from Stanford’s web site and modified for use at UT Dallas.