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.
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.
The Crimea, Donetsk (DNR) and Luhansk (LNR) Regions of Ukraine
*Russia is subject to increasingly broad sanctions