The Office of Foreign Assets Control ("OFAC") administers and enforces economic and trade sanctions against targeted foreign countries, businesses, regimes, and individuals that the U.S. Government has designated as terrorists, narcotics traffickers, or 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 States. US citizens, permanent residents and protected individuals are generally prohibited from doing business with, including providing services to, individuals, entities or countries on this Specially Designated National (SDN) List without a specific license.
Because of this prohibition, it is necessary to screen all international individuals prior to engaging with them to make sure they are not on the Specially Designated Nationals or Blocked Persons list. All members of the Harvard Medical School community are required to comply with this screening process and with Export Control laws and regulations.
The types of research-related activities that may trigger the need for SDN Screening include, but are not limited to:
a. International Shipping
b. On-Line Educational Services
c. International Collaborations
d. International Financial Transactions, including paying someone or receiving payment from someone who is a foreign national, (e.g., talks, interviews, travel and lodging arrangements)
e. Hosting international visitors to Harvard laboratories and departments
f. Sponsoring visas (H1B, J1 or other)
Any matches should be forwarded to the HMS Office of Research Administration Export Control Administrator for determination before further transactions with the individual or entity. The Export Control Guidance on Specially Designated Nationals screening provides further information on how to conduct SDN screens. You should also reference the points to consider when travelling abroad in the Foreign Travel Issues section of the Harvard Export Control website. Contact International_Collaborations@hms.harvard.edu with any questions or concerns or to request a screening.
If the Restricted Party Screening review determines that a license is required, an export license must be obtained prior to conducting business with the restricted individual or entity. The HMS Office of Research Administration Export Control Administrator will assist you with applying for a license prior to shipment or transfer. Please note that it can take 12 weeks or longer to receive a decision on a license application.
Resources
Appointments with Restricted Party Affiliations Guidance
Export Control Guidance on Specially Designated Nationals
Harvard Export Control Website
Onboarding & Employment Screening Fact Sheet
Request support or reviews at: International_collaborations@hms.harvard.edu