INTERNATIONAL COLLABORATIONS
In nearly all instances, the exchange of scientific information or publicly available information does not raise export control concerns. However, the limitations imposed by export control laws and regulations are dependent not only on the type of engagements being considered, but also the individuals, entities, and countries in question.
The U.S. government has identified certain individuals, entities, and countries that may not be engaged by the University without first obtaining a license from the appropriate government agency. The table below provides an outline of the individuals, entities, and countries that are held to a higher level of scrutiny under U.S. export control laws and regulations.
| DEPARTMENT OF STATE | DEPARTMENT OF COMMERCE | DEPARTMENT OF TREASURY |
|---|---|---|
| ITAR prohibits exports of "defense articles" or "defense services," to State Sponsors of Terrorism | EAR prohibits most interactions with Terrorist Supporting Countries (Group E:1) and countries with a Unilateral Embargo (Group E:2). | OFAC prohibits most interactions involving countries with Comprehensive Sanctions Programs. |
| • Cuba • Iran • North Korea • Syria |
Country Group E:1
• Iran • North Korea • Syria Country Group E:2 • Cuba |
• Crimea Region of Ukraine • Cuba • Iran • North Korea • Russia • Syria |
| ITAR maintains a policy of denial with certain countries for "defense articles" and "defense services." | EAR places restrictions on exports of military end-use or military end-user on certain countries. | |
| • Belarus • Burma (Myanmar) • China • Cuba • Iran • North Korea • Syria • Venezuela |
• Burma (Myanmar) • Cambodia • China, People's Republic of • Russian Federation • Venezuela |
|
| ITAR maintains specific policies of denial for certain countries for "defense articles" and "defense services." | EAR maintains sanctions programs for countries with Comprehensive Controls and Select Categories of Items. | OFAC prohibits certain interactions involving Countries with Limited Sanctions Programs. |
| • Afghanistan • Cambodia • Central African Republic • Cyprus • Democratic Republic of the Congo • Ethiopia • Eritrea • Haiti • Iraq • Lebanon • Libya • Russia • Somalia • South Sudan • Sudan • Zimbabwe *Country policies 22 CFR 126.1(f) – (w) |
Comprehensive Controls
• Cuba • Iran • Syria Select Categories of Items • Central African Republic • Crimea Region of Ukraine • Democratic Republic of the Congo • Eritrea • Iran • Iraq • Lebanon • Libya • North Korea • Russian Industry Sector Sanctions • Somalia • Sudan |
• Balkans • Belarus • Burma (Myanmar) • Central African Republic • Democratic Republic of the Congo • Ethiopia • Hong Kong • Iraq • Lebanon • Libya • Sudan • Venezuela • Yemen • Zimbabwe |
| ITAR's primary lists of restricted parties | EAR's primary lists of restricted parties | OFAC's primary lists of restricted parties |
| • Debarred List
• Munitions Export Control Order • Nonproliferation Sanctions List |
• Denied Persons List
• Entity List • Unverified List • Military End User List (MEU) |
• Specially Designated Nationals and Blocked Persons List (SDN)
• Foreign Sanctions Evaders List (FSE) • Sectoral Sanctions Identifications List (SSI) |
The various U.S. departments responsible for the administration of export control laws and regulations maintain lists comprised of certain "restricted parties." These lists are comprised of individuals, entities, and/or countries that have been identified as having or are suspected of having violated U.S. export control regulations and/or U.S. foreign policy. These lists are primarily maintained by the Department of Commerce, the Department of State, and the Department of the Treasury.
FAU has a responsibility to ensure that it and its community members' carry out the operations of the University in accordance with U.S. export control laws and regulations. This includes assessing whether FAU would be engaging those individuals, entities, or countries identified in the above referenced lists. This assessment is commonly referred to as a Restricted Party Screening (RPS), which should be performed prior to entering any agreement or engaging in any form of transaction. To do so, FAU uses Visual Compliance (see Visual Compliance page for additional information), which is a web-based platform accessible by any person with an email address under the FAU.edu domain name.
When to Perform a Restricted Party Screening
An RPS is to be performed prior to FAU engaging with foreign persons, organizations, or countries. Examples of such instances include, but are not limited to:
- International collaborations for FAU’s engagements (e.g., receiving funding, research, etc.)
- Foreign scholars, representatives, or visitors coming to an FAU-campus
- Visa applicants where FAU will act as the visa-sponsor
- International travel by an FAU community member for FAU-supported activities
- International shipments made by an FAU community member for FAU-supported activities
- International financial transactions for FAU-supported activities
Persons and Organizations of Concern
Department of Commerce – BIS – Export Administration Regulations (EAR)
Department of State – DDTC – International Traffic in Arms Regulations (ITAR)
Department of the Treasury - Office of Foreign Assets Control (OFAC)
Countries of Concern
Department of Commerce – BIS – Export Administration Regulations (EAR)
Department of State – DDTC – International Traffic in Arms Regulations (ITAR)
Department of the Treasury - Office of Foreign Assets Control (OFAC)
State of Florida - Foreign Countries of Concern (§ 286.101, § 288.860, Fla. Stat.)