Prohibited Individuals and Entities
There are some limited exceptions:
- Yale may apply for a license to conduct certain kinds of transactions, transfer materials or data, or provide services to individuals and entities in sanctioned and embargoed countries. Keep in mind that the process of preparing and obtaining licenses can be lengthy and time-consuming.
- The U.S. Government may issue a general license that establishes parameters within which particular kinds of activity may be allowed by specific categories of persons under certain conditions.
- Some sanctions programs restrict transactions of a particular type, rather than impose a comprehensive ban. For example, the Excluded Parties List contains the names of those who have been excluded from receiving federal funding. The Commerce Denied Persons list describes those who are prohibited from participating in U.S. export transactions. Other types of transactions with individuals and entities on those lists are not prohibited, unless the same individuals/entities also appear on one or more other lists (such as the OFAC Specially Designated Nationals list).
For assistance with licensing and questions about individual and entity prohibitions, contact Donald Deyo, Director of Corporate Contracts and Export Control Licensing.