Sanctions

From a March 9th email:

Dear Colleagues,

The email below, from UCLA’s Office of Export Control, contains important guidance pertaining to business we might conduct with foreign entities.

Some of you may have received this notice already, but given the current international landscape, we are now sharing this broadly. As you conduct business with foreign entities, please be mindful of sanctioned countries, regions, and in some cases, individuals.

Engaging in a sanctioned entity could result in significant penalties for the university. To help prevent this, please consult with your fund manager before initiating any business with a foreign entity. Your fund manager can support you with restricted-party screening to ensure there are no sanction-related concerns.

If you contact the Office of Export Controls directly, we kindly ask that you keep your fund manager included in that discussion.

Thank you for reviewing the information below and for completing the pre-screening procedure before engaging a potential foreign vendor or foreign individuals.

Kind regards,

xxx

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From: UCLA Export Controls <xxx@xxx.edu>

Date: February 13, 2026 at 5:10:19 PM PST

Cc: UCLA Export Controls <xxx@xxx.edu>, ...

Subject: Activity Restrictions with Sanctioned Countries

Dear CAOs and CFOs:

The U.S. Office of Foreign Assets Control (OFAC) administers and enforces comprehensive sanctions on certain countries and regions.  As of today, these are:

1. Cuba
2. Iran
3. North Korea
4. Crimea, Donetsk, and Luhansk regions of Ukraine

Please also note:

Russia remains heavily sanctioned.  While not comprehensively sanctioned in the same way as the countries/regions above, many activities involving Russia are restricted.

Although no longer subject to comprehensive sanctions, targeted sanctions on Syria may still apply.

Please visit OFAC Sanctions Programs and Country Information https://ofac.treasury.gov/sanctions-programs-and-country-information for current information.

Impact on UCLA

Comprehensive sanctions generally prohibit most activities with these countries and regions, including entities and individuals ordinarily resident/located there, unless specifically authorized by the U.S. government through a license.  These prohibitions apply regardless of whether the performance of the activity uses UCLA funds or resources.  The impacted UCLA activities include, but are not limited to:

1. Business or academic travel (including attending or presenting at a conference or award ceremony)
2. Imports/Exports (e.g., research samples, equipment, software, artwork)
3. Academic Collaborations (formal or informal, virtual or in-person)
4. Research Activities (data sharing, analysis, mentoring, joint publications)
5. Teaching or guest lecturing (including virtual talks/webinars to audiences in these locations)
6. Financial transactions (e.g., payments, honoraria, subawards, reimbursements, fee waivers)
7. Procurement of goods and services (including hiring remote independent contractors)
8. Sales and service activities
9. Paid or pro bono patient consultation and care
10. Remote work
11. Remote/online learning

The U.S. government has the discretion to impose civil and/or criminal penalties (financial penalties, imprisonment) on the institution and the individual(s) involved for violations of export controls and sanctions.

What To Do

The UCLA Export Control team serves as the campus point of contact for all export control and sanctions matters and is responsible for submitting license applications.  While UCLA has been successful in obtaining licenses from the U.S. government in the past, the process can take several months, so early consultation is essential.  Before initiating activities involving a comprehensively sanctioned country or region, please contact the UCLA Export Control team at xxx@xxx.edu.  We would be very happy to work with you.

Please feel free to share this message with your faculty and staff.

xxx

Director of Export Controls