Sanctions and Embargoes: Country Lists and Programs
The U.S. Government implements sanction programs against countries and entities that pose a national security concern or engage in activities that are contrary to foreign policy. For instance, humanitarian rights violations, regional stability, national security, or biological or nuclear concerns. Sanctions programs are administered by multiple federal government agencies as a result of unilateral imposed controls or are in place to implement United National Security Council Resolutions in coordination with U.S. NATO and non-NATO allies. More than one agency imposed sanctioned program can apply to your research activity or travel abroad.
Embargoed Countries (BIS controls):
|● Belarus||● Iran||● Syria|
|● Cuba||● Russia|
|● North Korea||● Sudan|
Proscribed Countries (ITAR controls):
|● Afghanistan||● Eritrea||● Russia|
|● Belarus||● Ethiopia||● Somalia|
|● Burma||● Haiti||● South Sudan|
|● Cambodia||● Iran||● Sudan|
|● Central African Republic||● Iraq||● Syria|
|● China (PR)||● Kyrgyzstan||● Venezuela|
|● Cuba||● Lebanon||● Zimbabwe|
|● Cyprus||● Libya|
|● Democratic Republic of the Congo||● North Korea|
To see additional prohibitions under other jurisdictions, please see below.
The U.S. State Department, Directorate of Defense Trade Controls (DDTC): Proscribed Country List.
The DDTC has a policy denial for licenses and other approvals for exports and imports of items or technologies that are destined for or originating in certain countries. Here's the list:
The U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC): Country Sanction Programs.
OFAC's economic and trade sanctions programs has a long reach that encompasses many transactions including those taking place outside the U.S., such as these: financial transactions--procurements, bank/wire transfers, donations--import/export, end-user, and country-based sanction programs.
The U.S. Department of Commerce, Bureau of Industry and Security (BIS): Embargoed Country List.
Activities involving embargoed countries will have more restrictive controls including those involving low-level technologies transfers to non-U.S. persons or entities. License requirements and prohibitions will vary depending on the country, technologies, end-use, and end-user controls.
Please refer to the International Travel page for information regarding travel abroad activities.
Special Alert - Russia and Belarus Sanctions
Immediate departure advised.
The State Department advised U.S. citizens to depart from Russia immediately in a travel advisory announced on Saturday. The announcement cited the invasion in Ukraine, the "potential for harassment against U.S. citizens by Russian government security officials" and the Embassy's limited ability to assist its citizens in the country.
Russia, all LNR and DNR regions of Ukraine and Crimea, Belarus Sanctions
As of February 21, 2022, the United States and its allies released sanctions and export controls in response to Russia's invasion of Ukraine1. This includes blocking sanctions on most major Russian banks including Russia's central bank, and removed certain banks from the SWIFT system, asset freezes on Russian elites, and a broad set of restrictions on exports of technology to Russia.
Washington, D.C.—The Department of Commerce, through the Bureau of Industry and Security (BIS), has issued a final rule that expands its highly restrictive controls on the export and reexport of U.S.-origin and certain foreign-produced commodities, software, and technologies to Russia and Belarus, further choking off access to inputs and products needed to sustain their military capabilities.
As a result of the rule, BIS has imposed highly restrictive license requirements on all categories of items on the Commerce Control List (CCL) to Russia and Belarus, which expands U.S. scrutiny of transactions to almost any sensitive dual-use technology, software, or commodities that could be used to support Russia's war effort. Furthermore, by applying a policy of denial to applications involving these items, the U.S. is effectively cutting off Russia and Belarus from access to a range of items. These restrictions should continue to severely degrade Russia's ability to sustain its aggression, as supported by Belarus.
Specifically, the new rule expands the license requirements on Russia and Belarus to all items designated on the CCL. This rule applies the additional restrictions established under previous Russia and Belarus rules to the three categories of unilaterally-controlled technology remaining on the Commerce Control List (CCL). These are Categories 0-2, which include materials and equipment relevant to nuclear, chemical, and materials processing. While the vast majority of items in Categories 0-2 already required a license for Russia and Belarus (or are subject to the licensing authorities of other agencies), this rule imposes new license requirements for items including certain composite materials, medical products containing certain toxins or genetically modified organisms, hydraulic fluids, pumps, valves, and lower-level machine tools.
In connection with this expansion in scope, the rule also applies the new Foreign Direct Product (FDP) Rules for Russia/Belarus and to Russian/Belarusian Military End Users (MEUs) to all items on the CCL. With limited exceptions, BIS will review applications involving all such CCL items under a policy of denial.
The rule took effect upon being released by the Federal Register on April 8, 2022 and is available here
In response to the Russian Federation's (Russia's) ongoing aggression against Ukraine, the Department of Commerce is expanding the existing sanctions against Russia and Belarus by imposing new export controls, including expanding the scope of the Russian industry sector sanctions to add lower-level items potentially useful for Russia's chemical and biological weapons production capabilities and items needed for advanced production and development capabilities to enable advanced manufacturing across a number of industries.
This rule also adds Belarus to the scope of industry sector sanctions that currently apply solely to Russia. With respect to end users, this rule expands the 'military end user' and 'military-intelligence end user' controls and applies the Russian/Belarusian-Military End User Foreign Direct Product (FDP) rule to ten existing entries for six existing entities that have continued to supply Russian entities on the Entity List or are under sanction since Russia's further invasion of Ukraine. Labeling these six entities as Russian `military end users' and applying the Russia/Belarus-Military End User FDP rule to them will degrade Russia's war efforts in Ukraine, as these entities produce items needed by the Russian and Belarussian military and industrial sectors. Correspondingly, this rule clarifies requirements related to Burma, Cambodia, the People's Republic of China, and Venezuela).
Finally, this rule refines existing controls on Russia and Belarus by adding additional dollar value exclusion thresholds for `luxury goods;' and makes twelve corrections and clarifications to existing controls on Russia and Belarus. The Department of Commerce is taking these actions to clarify and enhance the effectiveness of U.S. controls and to better align its controls on both Russia and Belarus with those implemented by U.S. allies.
The rule took effect upon being released by the Federal Register on September 16, 2022 and is available here
In response to the Russian Federation's (Russia's) ongoing aggression against Ukraine, as substantially enabled by Belarus, the Department of Commerce is expanding and strengthening the existing sanctions against Russia and Belarus, including the scope of the Export Administration Regulations (EAR)'s Russian and Belarusian industry sector sanctions and `luxury goods' sanctions. This rule also refines existing export controls on Russia and Belarus. The Department of Commerce is taking these actions to enhance the effectiveness of its controls on both countries and to better align them with those implemented by U.S. allies and partners.
The rule took effect upon being released by the Federal Register on February 27, 2023 and is available here
In response to the Russian Federation's (Russia's) ongoing aggression against Ukraine, as substantially enabled by Belarus, the Department of Commerce is strengthening its existing sanctions under the Export Administration Regulations (EAR) against Russia and Belarus, including by expanding the scope of the EAR's Russian and Belarusian Industry Sector Sanctions and by expanding the foreign direct product rule that currently applies to Russia and Belarus to apply to the temporarily occupied Crimea region of Ukraine as well. Additionally, this rule revises recent restrictions targeting Iran's supply of Unmanned Aerial Vehicles to Russia. This rule also refines existing export controls on Russia and Belarus. The Department of Commerce is taking these actions to enhance the effectiveness of its controls on these countries and to better align them with those implemented by U.S. allies and partners.
The rule took effect upon being released by the Federal Register on May 23, 2023 and is available here
Bureau of Industry and Security Controls: BIS significantly increased the license requirements on dual-use Items2 (hardware, software, technical data), including microelectronics, telecommunications Items, sensors, navigation equipment, avionics, marine equipment, and civil aircraft, exported, reexported or transferred in-country to Russia. These license requirements do not apply to deemed exports or deemed reexports. (BIS has jurisdiction over dual-use Items. Dual-use Items have military and commercial applications and are controlled by the US and Wassenaar Arrangement Countries3 for national security concerns.)
The sanctions impose export, reexport and transfer restrictions on Russia, all Luhansk People's Republic (LNR) and Donetsk People's Republic (DNR) regions of the Ukraine and Crimea4. The US and their allies have avoided the energy sector, with the exception of sanctions related to Nord Stream 2. Depending on the region, this means that exports of certain Items subject to the Export Administration Regulations (EAR) to designated entities or countries are prohibited. This includes low level Items that are not typically export controlled. In addition, BIS transferred 49 end-users to the entity list imposing additional restrictions on transactions that normally can occur without licenses. The EAR also restricts the use of certain license exemptions for exports, reexports and retransfers to Russia. Although we can submit licenses, BIS has announced a presumption of denial with certain exemptions for humanitarian reasons.
You will need to be aware that both financial dealings and physical imports and exports are subject to the new sanctions. Please contact our office or the Office of General Counsel if you have any questions, or anticipate engaging in any of these activities.
- Export/import to or from any of the sanctioned entities, countries or regions.
- Travel to these regions.
- Financial dealings with prohibited parties.
Please note that these sanctions are changing frequently.
Ukraine: On February 21, 2022 a Presidential Executive Order was issued imposing sanctions on Donetsk People's Republic (DNR) and Luhansk People's Republic (LNR) regions of Ukraine4.
Russia: Seventy-five entities (and subsidiaries thereof) and 19 individuals (and their families) in Russia have been designated as blocked persons (i.e., Specially Designated Nationals or SDNs), prohibiting U.S. Persons from conducting any business with them and requiring U.S. Persons to block their property and interests in property(5,6).
In addition, BIS moved 45 Russian entities that were on the Military-End-User List to the BIS Entity List, which enhances the export license requirements applicable to these entities. BIS imposed broad controls on 49 Russian entities that are similar to those imposed against Huawei Technologies Co. and its subsidiaries (collectively "Huawei"). These rules now control the export of all Items subject to the EAR with limited exceptions.
Belarus - Office of Foreign Assets Control: OFAC also added 16 companies (and their subsidiaries) and 8 individuals (and their families) to the restricted party list in Belarus in response to Belarus's support for the Government of Russia's invasion of Ukraine(5,6). (OFAC controls financial dealings with sanctioned countries and parties. Prohibitions apply even when there is no transfer of export controlled Items between a US Person and the sanctioned entity or country.)
3Wassenaar Arrangement List
Special Alert - New U.S Export Regulations For Advanced Computing and Semiconductor Items To and From China
On October 7, 2022, the Bureau of Industry and Security (BIS) published a new interim final rule that imposes controls on "certain advanced computing and semiconductor manufacturing items, supercomputer and semiconductor end use, and end-users." This rule applies when engaging with the People's Republic of China (PRC) (directly or indirectly) in semiconductor development and manufacturing of advanced computing and semiconductor chips. The restrictions apply to transactions to and from China of chips, commodities containing these chips, fabrication equipment for supercomputers and semiconductors. The rule also expects US exporters to know all the parties to a transaction, and to determine whether an item is destined for end-use in the development or production of ICs at a facility in China. It is recommended that you contact the export office before engaging with the PRC to assess the implications of these new requirements on your transaction, including procurements, development and fabrication activities, import/export of items to or on behalf of the PRC.