Understanding Restrictions on Specific Individuals and Entities

The U.S. government prohibits transactions (such as payments, trade, and exports) by U.S. persons with certain individuals or entities.   When U.S. persons conduct unauthorized transactions with such prohibited parties, they risk significant penalties including freezing of assets and ineligibility for federal awards.

To request additional information about U.S. government sanctions programs, contact the Office of the General Counsel.  To request information about screening a transaction, contact the contact the Director, International Agreements and Export Control Licensing (Office of Grant and Contract Administration). 

When would these restrictions apply to you?

If you are conducting transactions with other persons, whether individuals or entities and whether in the U.S. or abroad, these restrictions apply to you. Transactions may include:

  • Payments for goods or services (cash, check, wire transfer, or other means)
  • Contributions and donations of funds, materials or support
  • Shipments and trade

 

To request guidance or clarification contact the Office of the General Counsel or use the Contact Us link on the right.

 

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Are there any exceptions?

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).

Use the "Contact Us" link on the right to request guidance on the existence and applicability of exceptions, including licenses.

How can you avoid transactions with prohibited persons?

Use Yale’s systems for making payments, shipping items, and transferring materials.  Yale’s systems include screening processes to prevent transactions with prohibited parties.


If you must make a payment overseas outside of Yale's systems (e.g., an out-of-pocket expense which will be reimbursed later), have the transaction screened in advance.  Contact the Director, Corporate Contracts and Export Control Licensing for help.


Follow Yale policies and procedures related to financial transactions, shipping, materials transfers, and other international activities.   See Accounts Payable Policies and Procedures, including Policy 3401, Payment Policy, General and review Yale Business’ Express Shipping instructions.


Conduct appropriate due diligence when entering into any significant financial transaction, especially if the transaction will not be processed through Yale payment or shipping systems.


Contact the Director of International Agreements and Export Control Licensing (Office of Grant and Contract Administration) early to discuss applying for a license.  The process of preparing the application is time-consuming and the wait for review and approval by the U.S. government agency can be lengthy.


If you have a question or require additional help, use the “Contact Us” link on the right.

What are the possible costs of a violation?

Penalties vary based on the sanctions program.  Examples include:

  • Criminal penalties that can range into the millions of dollars for both the institution and individuals involved in the violation
  • Imprisonment (for example, up to 20 years for export control law violations)
  • Significant administrative fines/civil penalties that may be imposed per transaction
  • Denial of export privileges
  • Suspension or debarment from federal funding
  • Reputational damage
  • Ongoing government oversight

Related tools and resources

Yale Policies, Procedures and Guidance:

General