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Export Controlled or Sanctioned Countries, Entities and Persons

The US Department of the Treasury now requires export licenses for the export or import of ALL goods, services, or technology
to or from the Crimea, with the exception of certain agricultural commodities, medicine, and medical supplies.

When considering whether or not a shipment, transfer, transmission, or disclosure will In this section:
require an export license, we need to consider what is being shipped, where it is going, and
to whom it is being exported or disclosed. Overview

The lists on this page deal with "where" and "to whom" items, information, or software is Definitions
going (see the lists of controlled items, software, and technologies for guidance about what
may be sent). Openness in Research

Jump To: Export Controls Decision Tree

Tools and Checklists

Overview
Countries & Entities & Persons
Countries
Restricted Party Screening

Persons and Organizations

Export Controlled Items

A Note About Anti-Bribery Laws Temporary Exports

Forms

Confidentiality Agreements
Authority
DOR (Office of the Vice Provost and Dean of Research) Research and Encryption

H1-B Deemed Export Certification

Contact
Questions about this topic can be answered by: Penalties

Steven Eisner
Director of Export Compliance and University Export Control Officer
Vice Provost and Dean of Research
(650) 724-7072
steve.eisner@stanford.edu

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 Officer.

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 Steve Eisner, (650) 724-7072 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 (both available to the right on
this page). Given the numerous dual use export controls and Targeted Sanctions on
Iraq, you should contact Steve Eisner before engaging in activity with persons or
organizations in that country.

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Countries

Comprehensively Sanctioned Countries

Office of Foreign Assets Control Regulations - OFAC

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

Export Administration Regulations - EAR

Crimea Region of the 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, 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.

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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.

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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 a preferred
carrier such as Tigers Global Logistics in Hayward, CA.

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

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Date published Policies Items

February 15, 2019

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