UC Santa Barbara is committed to supporting global engagement and an open research environment. Our researchers participate in an extensive network of engagements, including international collaborations, involving collaborators from across the globe. At the same time, we must ensure that international collaborations follow U.S. laws and regulations. Those engaging in international collaborations play an important role in proactively identifying risks associated with these engagements. The following guidance is intended to help UCSB personnel identify international collaborations that may involve export control or similar restrictions. 

UCSB personnel are encouraged to consult with the Export Control Officer (exportcontrol@research.ucsb.edu) whenever they have questions on this topic.

 

 

Restricted Party Screening

In some cases, there may be restrictions on your specific research activities, shipments, or travel. This means that permission may need to be obtained from the U.S. government prior to engaging in those activities. Restricted party screening is used to identify restricted parties prior to engaging in activities which could result in export control violations. Export control regulations prohibit UCSB from engaging in certain transactions with specified foreign individuals or organizations, which may include foreign government officials or academic institutions. 

If a positive match is found, please consult with the Export Control Officer before proceeding. 

 

Embargoed or Sanctioned Countries

The Office of Foreign Assets Control imposes economic sanctions on foreign countries and individuals. The following countries and regions are subject to comprehensive sanctions.

In order to avoid inadvertently engaging in a restricted activity and so that we can help determine whether a license is required, you must consult with the Export Control Officer prior to traveling on university business, shipping or taking any university-owned items, or engaging in research collaborations with individuals located in these countries. With very few exceptions, a license is required from the U.S. government in order to engage in any financial transactions or services (e.g., traveling on University business, attending conferences, meeting with government officials, collaborating on research, or publishing research results) in these countries. Such licenses can take several months to obtain and may be subject to a presumption of denial. In some cases, general licenses may allow certain activities. All of these situations must be reviewed by the Export Control Officer before proceeding.

  • Cuba
  • Iran
  • Syria
  • North Korea
  • Crimean Region of Ukraine
  • Luhansk Region of Ukraine
  • Donetsk Region of Ukraine

 

Sanctioned & Restricted Foreign Universities

A number of foreign universities and research institutions are subject to one or more export control restrictions. The following list is not intended to be comprehensive, but contains most foreign universities that appear on U.S. government lists as of February 2024. For each university the list indicates whether it is subject to OFAC sanctions, on the Entity List, on the Unverified List, on the Department of Defense’s 1286 list, or any combination thereof. Restrictions associated with each of those government lists are described below.

  • List of Restricted Foreign Research Institutions & Universities (updated November 7, 2024)
    • On October 30, 2024 the Office of Foreign Access Control added a number of Russian institutions to their sanctions list.
    • On July 19, 2024 the Department of Defense updated their 1286 list, adding a significant number of new entities.
    • On May 14, 2024, a significant number of Chinese entities were added to the U.S. Department of Commerce's Entity List. These entities are involved with emerging and critical technologies, such as quantum computing, artificial intelligence, and microelectronics. One of the newly added entities is the University of Science and Technology of China (USTC) and several locations at the Chinese Academy of Sciences.

 

 

OFAC - Any collaboration, even informal, with an OFAC sanctioned university must be reviewed by the Export Control Officer prior to engaging in the collaboration. OFAC prohibits U.S. persons from providing services to sanctioned universities and those affiliated with those institutions. Obtaining permission from OFAC to engage in a research activity with a sanctioned university is not likely.

Entity List - These universities are subject to restrictions on shipping almost any physical items or sharing controlled software or technology. Such restrictions also apply to individuals employed by these universities, even when visiting the U.S. or another country. Export licenses may be required prior to shipping items to, or hosting a visiting scholar from, one of these institutions. In addition, certain U.S. sponsors may require risk mitigation measures be put in place for UCSB investigators with active or recent collaborations with researchers affiliated with these institutions.

Unverified List - Universities on the unverified list are subject to significant restrictions on shipping or selling items to them and are not eligible for license exceptions. We are required to file an Automated Export System record for all exports to parties listed on the Unverified List and obtain a statement from such parties prior to exporting, re-exporting, or transferring to such parties any item subject to the EAR which is not subject to a license requirement.

DoD 1286 List - In 2023 the Department of Defense implemented a risk-based research security review process and published a list of foreign universities confirmed to have engaged in problematic activities. UCSB investigators receiving funding from DoD may be subject to research security mitigation measures by DoD if they have an apparent association with universities on this 1286 list, the Entity List, universities subject to OFAC sanctions, or collaborators participating in one of the foreign talent programs listed at the above link.