Prohibited Individuals and Entities
If you are using Yale’s systems for making payments and shipping abroad, you are already employing good practices since those systems automatically screen to prevent prohibited transactions. What if your transaction occurs outside of Yale’s systems? Does it matter if the transaction does not include the exchange of cash, but rather goods and services?
Here are some scenarios to consider that would require some due diligence to avoid a prohibited transaction.
- You travel to another country to conduct research and plan to engage someone local (a vendor or perhaps an individual) for short-term assistance.
- You are leading a group on overseas travel and part of your itinerary includes a humanitarian aid project to provide supplies and support to local community development groups.
- Your overseas research in an embargoed country has been issued a license from OFAC, allowing you to travel to that country and conduct your research. What about using a local vendor for your in-country needs, such as transportation, interpreting and translation services, logistics and more? Your OFAC license does not authorize you to conduct transactions with prohibited individuals and entities.