Sanctions & Embargoes
OFAC FAQs
OFAC Frequently Asked Questions (FAQs) (PDF)
OFAC General FAQs are provided for the benefit of all USF interested parties. Additional specific FAQs are provided to be used in conjunction with the general FAQs to assist faculty, employees, and students.
General FAQs
- What is OFAC?
The U.S. Department of Treasury, Office of Foreign Asset Controls (OFAC) administers U.S. sanctions against Iran, Cuba, North Korea, and various other countries. There are serious penalties for violations. The University has a strong commitment to its academic mission, which must be balanced with the obligation to comply with U.S. law. - What types of sanctions exist?
Comprehensive Sanctions: Generally prohibits all direct or indirect imports/exports, trade brokering, financing, or facilitating against most goods, technology, and services. Transactions will require a specific license or an approved exception before the transaction can take place.
Limited Sanctions: Block specific practices, such as diamond trading. Most research and business activities may be conducted without an OFAC special license, so long as specific criteria are met as outlined in the regulations for a General License.
Regime or List Based Sanctions: Blocks specific property of targeted foreign governments, regimes, supporters, and persons that are not necessarily country-specific, but which may be owned, controlled by, or acting for or on behalf of, targeted countries or entities as a front organization. Collectively, such targeted individuals and entities are called "Specially Designated Nationals." - What does one mean by "prohibited transactions"?
Prohibited transactions are trade or financial transactions and other dealings in which U.S. persons may not engage unless authorized by OFAC or expressly exempted by statute. Because each program is based on different foreign policy and national security goals, prohibitions may vary between programs. - What types of transactions are prohibited?
- Exportation, importation, or sale of goods may be prohibited.
- Exportation, importation, or provision of services, including research and educational services may be prohibited.
- Provision of financial services or transactions involving a blocked entity, blocked person or comprehensively sanctioned country are prohibited.
- It is important to contact the USF Office of Export Controls if you are working with
a person or entity in a country with OFAC Sanctions. These countries are deemed countries of concern by USF and require review.
- Are there exceptions to the prohibitions?
Yes. OFAC regulations often provide general licenses authorizing the performance of certain categories of transactions. OFAC also issues specific licenses on a case-by-case basis under certain limited situations and conditions. - What are examples of exceptions?
Information and Informational Materials (License Exemption): Allows for importation and exportation of information or informational materials already in the public domain; however, it does not authorize financial transactions or services of value.
"Information and informational materials" includes publications, films, posters, phonograph records, photographs, microfilms, microfiche, tapes, compact disks, CD ROMs, artworks, and news wire feeds.
This authorization does not apply to materials not fully created and in existence at the date of the transaction.
This authorization also does not apply to the export of software or technology subject to export controls.
Authorized transactions necessary and ordinarily incident to publishing (general license): Allows for activities in support of publishing
OFAC has indicated that it does not consider a dissertation or academic thesis to be a published work under this authorization. Therefore, this authorization does not apply to activities in connection with preparing, defending, or advising on a dissertation or academic thesis. - What is a license?
A license is an authorization from OFAC to engage in a transaction that otherwise would be prohibited. There are two types of licenses: general licenses and specific licenses.
A general license authorizes a particular type of transaction for a class of persons without the need to apply for a license.
A specific license is a written document issued by OFAC to a particular person or entity, authorizing a particular transaction in response to a written license application.
Persons engaging in transactions pursuant to general or specific licenses must make sure that all conditions of the licenses are strictly observed.
The USF Office of Export Controls is available to apply for specific licenses on behalf of USF when necessary. - What are examples of prohibited services?
Advising a student on a dissertation or thesis when the student is located in a comprehensively sanctioned country.
Providing educational services in the form of distance learning, class instruction, grading, and return of coursework or exams, research advising, or exchange of unpublished course information. This would include examples including activities such as: allowing an individual located in Iran access to group research meetings via Skype; or allowing a student to submit course assignments for grading from Iran.
Provision of business services such as ßÙßÇÂþ» email, CANVAS, Remote Desktop Gateway (RDG) or other internet-based services requiring a USF NETID to access.
Provision of educational services related to research, such as accepting data or samples from a comprehensively sanctioned country, providing analysis of those samples and returning the data set.
Importing research samples or datasets from a comprehensively sanctioned country, even if there is not a monetary value to the samples. For example, if a professor travels to Cuba under the auspices of a general licenses to conduct research in Cuba, the professor would not be allowed to collect and import research samples back to the United States without a specific license from OFAC.
Provision of financial services to an individual in a sanctioned country or in a third country without a valid visa. This would include payment for services such as teaching or research, even if the payment went to a US bank account. - Correspondence via telecommunication or mail
Is authorized under certain instances, such as:
If a person physically located in a sanctioned country contacts me to discuss my research, can I share information with them? It is acceptable to share pre-created information that is in the public domain. Feel free to send a copy of your CV or a link to your open source website.
A student has applied from a sanctioned country. I would like to offer them a position at USF as my graduate research student. Can I communicate this to them through a letter? Yes. It is legal to correspond with individuals in sanctioned countries to exchange public information or information related to a planned student visa.
Can I send a student in a sanctioned country the syllabus to my course, if they are planning to attend the course on-campus in the United States? You can send them a link to a website that does not require login where the syllabus is posted. However, you are prohibited from providing educational guidance or requiring the student submit assignments prior to their arrival in the United States. - Iranian Sanctions - what do I need to know?
For guidance on what is allowable involving Iranian sanctions, please visit our Iran Sanctions page. - Travel to Cuba - what do I need to know?
For guidance on how to legally travel to Cuba under the auspices of USF business, please visit our Cuba page. Specific assistance is also available from USF Office of Export Controls by email or calling 813-974-6368.
Questions for Faculty and Employees
- If I travel to Cuba on an authorized general license, can I access my.usf.edu from
Cuba?
You will not be able to access web interfaces requiring a NETID login while in Cuba, including CANVAS, GEMS, FAST, Remote Desktop Gateway, etc. as this is considered the export of a business service to Cuba. However, you are able to access your email through a downloaded email client on your cell phone as long as it is operational prior to leaving the United States, as this falls under a different regulation. - If I am an Iranian national and I need to travel home, can I continue to work while
I am away?
Unfortunately, you will be unable to work while in Iran, as this is an import of prohibited services to USF from Iran. Additionally, you will be unable to be paid or access my.usf.edu while in Iran. - If I am invited to speak at a conference in Iran, North Korea, Sudan or Syria under
the auspices of my employment at USF, is this allowable?
In addition to the restrictions of OFAC, requiring a specific license to speak at a conference in one of these countries, , mandates that no state funds may be used to facilitate travel to a country listed as a by the US Department of State. Therefore, an individual may not travel to one of these countries on USF business at this time. - If one of my students travels home to a comprehensively sanctioned country for personal
reasons, can they continue to work on our collaborative research project while they
are abroad?
Due to the prohibition of the export of educational services to a comprehensively sanctioned country without prior authorization from OFAC, you are not be able to continue to process research samples or export data to the student while they are in a comprehensively sanctioned country. - If one of my students wants to do research for their thesis in a sanctioned country,
is that allowable?
A license may be required for participation in research located in a sanctioned country. Please contact the Export Control Officer by email for more information. - Can I post grades to CANVAS if I know one of my students is from a sanctioned country?
Since access to CANVAS is blocked from users who are physically located in sanctioned countries, you are free to post grades for students on CANVAS regardless of citizenship.
Questions for Students
- Why is my country blocked from accessing my.usf.edu?
As you may know, certain United States export control regulations prohibit U.S. businesses, such as USF, from offering services to users in sanctioned countries. Participating in distance learning from USF is considered a "service." Under U.S. export control regulations, exporting a "service" to Cuba, Iran, N. Korea, and Syria are prohibited. - How do I access my student email account, if I can't login to my.usf.edu?
You will not be able to log into your @mail.usf.edu email address while physically located in Cuba, Iran, N. Korea or Syria, as this service is accessed through my.usf.edu. - What if I am a current student from a sanctioned country taking classes on campus,
can I still log into my.usf.edu?
As long as you are not physically located in Cuba, Iran, N. Korea, or Syria, you are able to log into my.usf.edu at any time. However, if you travel to one of these countries, you will not be able to login from that country. - If I am an applicant or current on-campus student, how can I register for classes
while I am located in a sanctioned country?
Enrolling in an on-line course and attending the course while physically located in Cuba, Iran or Syria is not allowable. If you are attempting to register prior to coming to the U.S. for on-campus courses, please contact the Office of the Registrar by calling 1-813-974-2000 or take a look at their contact page. - I am a potential student who currently resides in a sanctioned country. How can I
find out if I have been accepted to attend USF's on-campus program?
Please contact the Office of Graduate Studies by calling 1-813-974-5762 or by email.