Sanctions, Restricted Parties, and Restricted Party Screening

U.S. laws restrict certain types of collaboration and transactions with specific countries, organizations, and individuals. Before initiating  any international activity, such as a research collaboration, foreign travel, data sharing, or payment, George Washington University (GW) personnel should confirm that the people or organizations involved are not on a U.S. government restricted list and that any work involving a sanctioned country has been reviewed and approved.

The Research Security Office can help determine whether your planned activity is affected by these regulations. Faculty and staff planning to work with someone located in a sanctioned country, or with an individual or organization on a restricted list, should contact the exportcontrolgwu [dot] edu (Research Security Office) as early as possible to avoid delays or compliance issues.

• Restricted Party Screening using Visual Compliance
• Sanctioned Country Guidance
• Restricted Party Guidance

Restricted Party Screening 

GW has implemented Visual Compliance (VC) software to conduct Restricted Party Screening (RPS). VC is a simple way to identify potential sanctioned or restricted individuals and entities, and requires minimal recordkeeping, as all records are kept within the VC system.

Who Should Be Screened?

Screening may be conducted on international individuals and entities who engage with GW in a variety of ways, including (but not limited to):

• New GW employees
• Proposed visiting scholars and business visitors
• Research sponsors
• Research collaborators (individuals and their related institutions)
• Academic collaboration partners
• Potential vendors and service providers
• Potential donors
• Shipping recipients

For certain high-risk departments and activities, screening may be required for both domestic and international parties.

Screening Procedures

GW units are encouraged to conduct screening as early as possible prior to an engagement or transaction. If screening results in an actual match, contact the Research Security Office for further evaluation and assistance. 

Screening parties is not equivalent to conducting an export control review, but it is always the first step in a review. If your proposed activity otherwise raises export control risk due to the type of activity, third party requirements, country involved, etc., please screen the parties involved, and then escalate the activity to the Research Security Office at exportcontrolgwu [dot] edu (exportcontrol[at]gwu[dot]edu).

Request Access to Visual Compliance (VC)

The Research Security Office maintains GW’s license to Visual Compliance, and all GW personnel may have access to the software.  

If you need access to Visual Compliance or additional guidance, please contact the Research Security office at exportcontrolgwu [dot] edu (exportcontrol[at]gwu[dot]edu).

Sanctioned Countries 

The Office of Foreign Assets Control (OFAC) within the United States Treasury Department enforces all U.S. embargoes and sanction programs. Depending on the sanction/embargo program, different activities may or may not be prohibited without a specific government authorization or license.

OFAC does not per se regulate access to specific laboratory equipment, technical data and research results the way that the EAR and ITAR do. Rather, OFAC regulations govern financial transactions and certain services with embargoed and sanctioned countries, entities, and individuals. Examples of OFAC-governed transactions include (but are not limited to):

• Making payments to or receiving money from individuals or entities subject to embargoes and/or sanctions
• Receiving gifts from a donor or other party that is a restricted party, or is a national of a sanctioned country
• Collaborating with an institution in Iran or Russia (even if only data is transferred)
• Transferring commodities or materials to an OFAC-restricted country
• Importing items (including artwork, artifacts, books, etc.) from a sanctioned country
• Providing editorial comments directly to a foreign national located in an OFAC-restricted country as part of a journal or peer review
• Advising on procurement or laboratory-set up activities; or research methodologies
• Travel to Iran for any professional purpose (e.g. conference, research, teaching)

OFAC sanction programs can be generalized into three categories:

• Comprehensive: In general, under comprehensive sanctions programs, ALL interactions and activities are prohibited, including exporting to, importing from, financial transactions of any kind, and/or providing services of any kind. While essentially all interactions with comprehensively sanctioned countries are prohibited, there is an exception for informational materials that allows certain transactions to occur. Currently, the “comprehensively” sanctioned countries include Cuba, Iran, Russia, and North Korea.
• Limited: Under limited sanctions programs only some activities (e.g., importation of items) are prohibited.
• Regime or List-Based: Regime or List-Based sanctions are targeted against specific individuals identified by the Treasury Department and referred to as Specially Designated Nationals (SDNs) or are targeted against specific groups of people usually associated with a governmental body or regime.

For additional information on a specific sanction program, see OFAC Sanction Program Summaries.

If you don’t know whether your transaction or engagement is subject to OFAC regulations, the Research Security Office can help! Likewise, if you wish to engage with an individual who is based in a sanctioned country or an individual who is a restricted party, please exportcontrolgwu [dot] edu (contact us) as soon as possible.

Restricted Parties

U.S. export control regulations (including Department of Commerce Export Administration Regulations, Department of State International Traffic in Arms Regulations, and Department of the Treasury Office of Foreign Asset Control Regulations) include listings of ‘restricted parties’ for whom many export transactions are prohibited or significantly restricted. The restrictions for these individuals and companies can include exporting, re-exporting, deemed exports, services or special licensing requirements. Such Restricted Parties include both foreign persons and U.S. citizens/entities, and a number of international institutions of higher education are Restricted Parties.

Export transactions involving restricted individuals and entities are generally prohibited without an export license or other approval, including the transfer of EAR99 items (ex. clothing, toiletries, briefcases, etc.) and technology.