As you may have seen in recent headlines, certain countries such as China, Russia and Saudi Arabia, have been the focus of targeted US sanctions. These sanctions have resulted in individuals and entities from these countries being newly deemed as “Specially Designated Nationals”, meaning that U.S. persons are generally prohibited from dealing with them.
These recent developments, and the potential for further congressional and/or executive action in areas of US sanctions and Export Control reforms, should serve as a reminder to us all that the University’s long-term ability to engage broadly and openly with potential donors, scholars and collaborators here and around the world depends upon our awareness and consideration of these regulatory issues. While these regulations apply directly to University activities, they also apply to individuals’ outside activities (e.g., serving on an advisory committee or consulting) and federal funding agencies expect compliance with these matters in both university and outside relationships.
To that end, I write to encourage your administrators and faculty to conduct appropriate diligence on individuals and organizations with whom they are engaging, both on campus and abroad. The University has specific resources to support these screening and diligence efforts, which are listed below:
For potential donors: David W. Cashman, Senior Director, International Advancement (email@example.com; 773-702-5113)
For potential research collaborations or sponsors: Disrael Sanchez-Rodriguez J.d., Export Control Compliance Manager, University Research Administration (firstname.lastname@example.org; 773-702-8601)
All other relationships: Katie Hrinyak, Executive Director, Operations and Strategy (email@example.com; 773-834-1559)
Similarly, if your faculty or staff are contemplating any research or transactional activity within or involving an OFAC-sanctioned country (as described below), please contact Disrael Sanchez-Rodriguez, J.D., Export Control Compliance Manager and Smita Singh, Assistant General Counsel (firstname.lastname@example.org; 773-702-7239) for assistance before proceeding.
Additional background information on US Sanctions Programs and Specially Designated Nationals is below. If your unit would like to receive further information and/or trainings on these topics and related obligations, please contact Stefan Jellicoe.
US Sanctions Programs: The Department of Treasury’s Office of Foreign Asset Control (OFAC) administers US sanctions programs which involve the blocking of assets and trade restrictions to accomplish foreign policy and national security goals. These US sanctions programs vary in scope;
some are broad-based and geographically oriented (i.e. Cuba, Iran) while others are “targeted” towards certain policy goals (e.g., counter-terrorism, human rights violations, election interference, counter-narcotics) and focus on specific individuals and entities. OFAC maintains a list of these sanction programs here.
Specially Designated Nationals: OFAC maintains a list of individuals and entities that are the target of a US sanction program (known as the “Specially Designated Nationals and Blocked Persons list” or “SDN List”), which includes approximately 6,400 names of individuals and organizations, including foreign universities, who are connected with the sanctions targets. U.S. persons are prohibited from dealing with SDNs wherever they are located and all SDN assets are blocked. Importantly, entities that are 50% owned (directly or indirectly) by an individual on the SDN List are also blocked, regardless of whether that entity is separately named on the SDN List. The University utilizes a tool called “Visual Compliance” to screen named individuals and companies against the SDN and similar lists. The following administrative units have access to this tool: ARD, Global, URA, and Procurement and Shared Services within central F&A.
Penalties for Non-Compliance: Penalties for violating US sanctions apply to individuals and corporations and vary depending on the underlying sanctions program. For example, violations can result in criminal penalties of up to $1 million per violation for corporations and $250,000 or up to twenty years in prison (or both) per violation for individuals. Civil penalty maximums can range from approximately $78,000 to over $1 million per violation.
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