Sanctioned and Embargoed Countries

Sanctioned and Embargoed Countries

The U.S. Department of Treasury, Office of Foreign Assets Control (OFAC) maintains lists of countries subject to U.S. economic and trade sanctions. These sanctions can take the form of some countries with comprehensive embargoes and sanctions, and other countries with more targeted sanctions. Comprehensively sanctioned and embargoed countries, where virtually all transactions are prohibited, currently include Cuba, Iran, North Korea, and the Ukrainian regions of Crimea, Donetsk, and Luhansk. Targeted sanctions, which restrict specific activities or dealings, are in place for many other countries, such as Belarus, Russia, Syria, and Venezuela.  

MSU is required to review compliance risks for engagement in sanctioned countries that the U.S government has determined present elevated risk. The U.S. government has grouped these sanctioned countries into categories, with different levels of compliance review required depending on MSU’s engagement with the sanctioned country, or individuals located in the sanctioned country. The following countries present compliance risks that will need to be reviewed by MSU’s Office of Export Control and Trade Sanctions (ECTS) before proceeding.  

Comprehensively Sanctioned and Embargoed Countries 

The comprehensively embargoed and sanctioned countries are subject to broad political, military and economic sanctions through executive orders and federal law.  Without an export license, MSU personnel are prohibited from transacting funds with, and providing services into, the following U.S. government comprehensively embargoed countries:

• Iran 

• Cuba 

• North Korea 

• Crimea, Donetsk People’s Republic, and Luhansk People’s Republic regions of Ukraine 

MSU personnel are not permitted to conduct any MSU-related business, including research, educational services or online learning, with entities or residents located in the comprehensively sanctioned countries without an export license. Please contact MSU’s Office of ECTS if your proposed research or teaching involves people or entities located in comprehensively sanctioned or broadly sanctioned countries. 

Targeted Sanctions

While not all activities in these countries are prohibited, Belarus, Russia, Syria, and Venezuela are all heavily sanctioned by the U.S. Government.  All proposed MSU-related business activities, including research and online coursework, must be reviewed by MSU’s Office of ECTS in advance to confirm that an export license is not needed before proceeding.  Further details on each country with targeted sanctions is below. 

• Syria:  The U.S. government has recently issued General License 25, which effectively suspended comprehensive U.S. sanctions on Syria. However, an export license from the U.S. Commerce Department is still required for the export of all items subject to the Export Administration Regulations (EAR), and therefore, most transactions involving U.S. goods, software, or technology (including data) are still restricted to Syria. Any proposed activities in Syria need to be reviewed to ensure that EAR-controlled items and technology are not being provided to Syria. Contact MSU’s Office of Export Control and Trade Sanctions (ECTS) for up-to-date guidance on working with individuals and entities in Syria.

• Venezuela: Interactions with government-owned businesses in Venezuela, including many banks and universities, are limited.  There are numerous issues to navigate to confirm MSU’s proposed engagement does not have ties to the Venezuelan government or other blocked parties.  Contact MSU’s Office of Export Control and Trade Sanctions (ECTS) for up-to-date guidance on working with individuals and entities in Venezuela.

• Russia and Belarus: Interactions with entities and individuals located in Russia and Belarus are currently significantly restricted. Contact MSU’s Office of Export Control and Trade Sanctions (ECTS) for up-to-date guidance on working with individuals or entities in Russia and Belarus.