Export Control: International Financial Transactions


University activities that include the payment of funds to non-U.S. persons abroad must ensure that the university does not inadvertently provide financial assistance, or anything of value, to a blocked or sanctioned person or entity. These transactions could include payment to a non-U.S. university subaward, guest speaker, or research vendor or participant in another country.

The University must not participate in any financial transaction with any entity or person found on any government issued restricted, blocked, or denied party list without first determining if a license is required. To avoid the inadvertent participation in a restricted transaction, Restricted Party Screening should be done to check new vendors and non-vendor payees against verification lists of restricted individuals and entities.

  • You must have a license to make payments to parties on the OFAC list .

The Treasury Department’s Office of Foreign Assets Controls (OFAC) administers and enforces economic and trade sanctions based on US foreign policy and national security goals against targeted foreign countries and regimes, terrorists, international narcotics traffickers, those engaged in activities related to the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the United State. OFAC has dozens of current sanctions programs, most notably Cuba, Iran, North Korea, Syria, and Ukraine (Crimea, Donetsk, and Luhansk Regions).

Not only are payments to certain entities prohibited, but certain services, sharing of information, and shipping items to certain entities could be prohibited due to these and other government sanctions. It is therefore important that you are aware of who you are participating with in any international transaction.

Supply Chain Management Procurement can help determine if items purchased through their office have any applicable export controls. Accounts Payable utilizes Visual Compliance on a daily basis to screen payments to international vendors and identify potential flags.

Contact the Export Control Officer if you have questions about an activity that involves payment to persons or organizations outside the U.S.