Foreign Universities Sanctioned by the U.S. Government
Foreign Universities Sanctioned by the U.S. Government
The U.S. government designates various entities including universities, research institutions, companies, non-profit organizations and affiliates to various prohibited party lists. Each party will need to be reviewed individually as each transaction is subject to different restrictions, and each entity is subject to prohibitions that constantly change due to foreign policy, national security or other issues of concern.
BIS Entity List (U.S. Department of Commerce)
The following universities and research entities are an example of the institutions that appear in the U.S. Department of Commerce, Bureau of Industry and Security "Entity List." The Entity List includes individuals, companies, research institutions, non-profits, affiliates and subsidiaries. An export license or other government approval will most likely be required to export, re-export items or to conduct transactions with a sanctioned party.
This list is not a comprehensive list and the entities are updated periodically by the government. The complete list is published and updated periodically here: Supplement No. 4 to 15 CFR § 744.
Please contact the Office of Export Compliance if you wish to engage with an institution or wish to host a visitor affiliated with an Entity List named party.
(Version date: 1/16/2024.)
| Country | Entity | License Requirement |
|---|---|---|
| China | Sichuan University | For all items subject to the EAR |
| China |
University of Electronic Science and Technology of China |
For all items subject to the EAR |
| China |
54th Research Institute of China, a.k.a.: -China Electronics Technology Group Corp. (CETC) 54th Research Institute; -Communication, Telemetry and Telecontrol Research Institute (CTI); and -Shijiazhuang Communication Observation and Control Technology Institute. |
For all items subject to the EAR |
| China | Beijing Institute of Technology |
For all items subject to the EAR |
| China |
Beijing University of Posts and Telecommunications |
For all items subject to the EAR |
| China |
Beijing University of Aeronautics and Astronautics (BUAA), a.k.a.: -Beihang University. |
For all items subject to the EAR |
| China |
Chinese Academy of Engineering Physics, a.k.a.: -Ninth Academy; -Southwest Computing Center; -Southwest Institute of Applied Electronics; -Southwest Institute of Chemical Materials; -Southwest Institute of Electronic Engineering; -Southwest Institute of Environmental Testing; -Southwest Institute of Explosives and Chemical Engineering; -Southwest Institute of Fluid Physics; -Southwest Institute of General Designing and Assembly; -Southwest Institute of Machining Technology; -Southwest Institute of Materials; -Southwest Institute of Nuclear Physics and Chemistry (a.k.a., China Academy of Engineering Physics (CAEP)'s 902 Institute); -Southwest Institute of Research and Applications of Special Materials Factory; -Southwest Institute of Structural Mechanics; (all of preceding located in or near Mianyang, Sichuan Province) -The High Power Laser Laboratory, Shanghai; -The Institute of Applied Physics and Computational Mathematics, Beijing; and -901 Institute. |
For all items subject to the EAR |
| China |
Northwestern Polytechnical University, a.k.a.: -Northwestern Polytechnic University; -Northwest Polytechnic University; and -Northwest Polytechnical University. |
For all items subject to the EAR |
| China |
National Supercomputing Center Guangzhou (NSCC-GZ), Sun Yat-Sen University |
For all items subject to the EAR |
| China |
National University of Defense Technology (NUDT) |
For all items subject to the EAR |
| China | Harbin Institute of Technology |
For all items subject to the EAR |
| China | Harbin Engineering University |
For all items subject to the EAR |
| China |
Hefei National Laboratory for Physical Sciences at Microscale |
For all items subject to the EAR |
| China |
Nanjing Institute of Astronomical Optics and Technology, a.k.a., the following one alias: - NIAOT. No 188 Bancang Street, Nanjing, 210042, China; and No 188 Ban Cang Street, Nanjing, 210042, China |
For all items subject to the EAR. |
| China |
Nanjing University of Aeronautics and Astronautics |
For all items subject to the EAR |
| China |
Nanjing University of Science and Technology |
For all items subject to the EAR |
| China | Tianjin University |
For all items subject to the EAR |
| China | Xinjiang Police College |
For all items subject to the EAR |
| Syria |
Higher Institute of Applied Science and Technology (HIAST), a.k.a.: -Institut Superieur des Sciences Appliquées et de Technologie (ISSAT); and -Institut des Sciences Appliquées et de Technologie (ISAT). |
For all items subject to the EAR |
| Russia |
Moscow Institute of Physics and Technology |
For all items subject to the EAR |
Unverified List (U.S. Department of Commerce)
The following universities and entities are an example of the institutions that appear in the Department of Commerce Entity "Unverified List" (UVL). Engaging with parties on the UVL may require an export license or other government authority before transfer. In particular, physical exports to these entities for certain commodities may be subject to prohibitions. The UVL parties are typically subject to lesser controls than the Entity List related to some research activities.
This list below is not a comprehensive list and the entities are updated periodically by the government. The complete list is published and updated periodically here: Supplement No. 6 to 15 CFR § 744.
Please contact the Office of Export Compliance if you wish to engage with a UVL listed party.
| Country | University/Institution |
|---|---|
| China |
Anhui Institute of Metrology |
| China | Shanghai Institute of Applied Physics |
| China | Guangdong University of Technology |
| China | Nanchang University |
| China | Sun Yat-Sen University |
| China | Hefei Institutes of Physical Science |
| China |
Southern University of Science and Technology, Department of Mechanical and Energy Engineering |
| China |
Hunan University, State Key Lab of Chemo/Biosensing and Chemometrics |
Foreign Universities Sanctioned by the U.S. Treasury Department
The following universities are an example of the institutions that appear on U.S. Treasury Department, Office of Foreign Assets Control's (OFAC) "Specially Designated Nationals" (SDN) list. The SDN list includes individuals, companies, research institutions and non-profits. The OFAC prohibitions blocks U.S. persons from dealing with them, including financial transactions. Transactions involving SDNs are subject to strict prohibitions and require a license or other government approval depending on the activities proposed.
OFAC administers a number of different sanctions programs. The sanctions can be either comprehensive or selective, using the blocking of assets and trade restrictions to accomplish foreign policy and national security goals of individuals and companies that are not country specific.
This list is not a comprehensive list and the entities are updated periodically by the government. The complete list is published and updated periodically here: OFAC Sanctions List Search.
Please contact the export office if you wish to engage with a SDN listed party.
(Version date: 1/16/2024.)
| Country | University |
|---|---|
| Iran | Malek Ashtar University Of Technology |
| Iran | Baqiyattallah University Of Medical Sciences |
| Iran | Imam Hossein University |
FAQs
A student's enrollment at a university included on the Bureau of Industry and Security Entity (BIS) List is a "red flag" which will require researchers undertake an additional level of due diligence before proceeding with a transaction. However, in some instances, a student is not considered by BIS to be an integral part of the university (e.g., does not have fiduciary duty to from the university in the same manner that as an employee, officer, trustee, or person in a similar position in the university would) in which he/she is enrolled and therefore BIS does not include them in the licensing requirements and policy specific to the university. With the caveat of the red flag mentioned above, BIS advises exporters to treat exports, reexports, and transfers (in country) to students as shipments to the country of which the student is a citizen (i.e., "Deemed Export"). The EAR defines a "release" of "technology" or source code in section 734.15 of the EAR.