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Information for Grantees Conducting Research in OFAC Sanctioned Countries

The Wenner-Gren Foundation supports grantees conducting research in countries all around the world.  We want to help you complete your project with our funding.  However we are obligated to follow U.S. laws regarding research in countries subject to US Government sanctions programs.  These countries are listed below, along with a description of the procedures you must follow to work in each of them.  Although we cannot guarantee the outcome of the US Government licensing process, or the speed with which a government agency will issue the necessary documents, we are committed to helping you develop a plan for acquiring the licenses and permissions you need.  

US Government sanctioned countries are those which are subject to restrictions under the US Department of Treasury Office of Foreign Assets Controls (OFAC) regulations, or embargoes or other special controls under the Export Administration Regulations, that could affect travel, exportations, importations or other transactions of a kind that may occur in connection with projects funded by the Wenner-Gren Foundation. Special permission in the form of a US Government license or other documentation is required for research projects located in Cuba, IranNorth Korea, Syria, Crimea (including Sevastopol)and Venezuela

All grantees must comply with US Government regulations. This is true even if the grantee is a non-US citizen based at a non-US institution because the Foundation is registered in the US and is therefore a US entity. By submitting an application to the Foundation, a non-US citizen based at a non-US institution gives the Foundation permission to apply for the necessary license or other required clearance to enable the Foundation to fund the research project located in a country subject to US Government sanctions.

It is the responsibility of US citizens based at US or non-US institutions and non-US citizens based at US institutions to supply the Foundation with the appropriate license or clearance at the time the grant is awarded. Applications can be made online here. The appropriate OFAC licensing category for Wenner-Gren grants is "transactional."

Compliance with the US Government sanctions programs is in addition to the prohibition of transactions with any person on the Specially Designated Nationals List (SDN List). Please consult the US Department of Treasury website at: www.treasury.gov/ofac for more information on US Government sanction programs and the SDN List. For information on Export Administration Regulations, please consult the US Commerce Department Bureau of Industry and Security (BIS) website here.

 

Research carried out in Cuba:

Funds cannot be disbursed by the Foundation without the following:

  1. For Doctoral Students based at US institutions
    • The student must supply a signed statement from the US institution stating that 1) the individual is a student currently enrolled in a graduate degree program, and 2) the grant will be used for noncommercial academic research in Cuba specifically related to Cuba and for the purpose of obtaining that degree.
  2. For Doctoral Students based at non-US institutions
    • Students based at non-US institutions may be able to claim coverage under the Office of Foreign Assets Control (OFAC) general license to engage in travel transactions in Cuba in connection with professional research. The general license can be found on the US Government website here. The OFAC general license covers full-time professionals whose travel transactions are for professional research directly related to the traveler's profession, professional background, or area of expertise, including area of graduate-level full-time study, and comprises a full work schedule in Cuba. The Foundation requires a signed statement from the student stating that he/she is traveling and researching under the terms of the OFAC general license and is in full compliance with the terms and conditions of that license.
    • In the event the OFAC general license does not cover the proposed travel and research activities, the doctoral student must apply directly to OFAC for an appropriate license and supply a copy to the Foundation. If the doctoral student is not a US citizen, the Foundation will need to apply to OFAC for a license to disburse funds. Applicants who are successful at Stage One of the Foundation's screening process should notify the Foundation if the OFAC general license does not apply to their particular situation.
  3. For Post-Ph.D. Scholars
    • Post-Ph.D. scholars may be able to claim coverage under the Office of Foreign Assets Control (OFAC) general license to engage in travel transactions in Cuba in connection with professional research. The general license can be found on the US Government website here. The OFAC general license covers full-time professionals whose travel transactions are for professional research directly related to the traveler’s profession, professional background, or area of expertise, including area of graduate-level full-time study, and comprises a full work schedule in Cuba. The Foundation requires a signed statement from the scholar stating that he/she is traveling and researching under the terms of the OFAC general license and is in full compliance with the terms and conditions of that license.
    • In the event the OFAC general license does not cover the proposed travel and research activities, the scholar must apply directly to OFAC for an appropriate license and supply a copy to the Foundation. If the scholar is not a US citizen, the Foundation will need to apply to OFAC for a license to disburse funds. Applicants who are successful at Stage One of the Foundation's screening process should notify the Foundation if the OFAC general license does not apply to their particular situation.
  4. Doctoral Students and Post-Ph.D. Scholars must confirm that the funds will not be used for any payments to or other transactions with an entity or sub-entity of the State Department's Cuba Restricted List. The list is available here.
  5. Shipment to Cuba of equipment, supplies or other items from the US, directly or indirectly, may be restricted by the US Export Administration Regulations (EAR). Doctoral Students and Post-Ph.D. Scholars are responsible for complying with the relevant requirements of the regulations. For more information on the regulations please consult the BIS website or the export compliance office at your institution.

 

Research carried out in Iran

US citizens based at US or non-US institutions and non-US Citizens based at US institutions:

The applicant, whether a doctoral student or Post-Ph.D. scholar, must apply directly to OFAC for a license to carry out the specific research project proposed to the Foundation or for an interpretive letter stating that no license is required. If the project contemplates the purchase of goods or services in Iran, or the exportation of goods or services from any country to Iran (other than goods or services necessary and incidental to travel or personal maintenance), that fact must be specifically noted in the application to OFAC. Funds cannot be disbursed by the Foundation without receipt of the license or a letter from OFAC stating that a license is not necessary.

Special circumstances – OFAC’s General License G

A license or letter from OFAC, however, will not be required where the research is authorized by OFAC’s Iran General License G, which allows US persons who are actively enrolled in a US academic institution to engage in noncommercial academic research at Iranian universities, subject to certain limitations.  A copy of that general license may be viewed here.  The Foundation will require a signed letter from the applicant’s U.S. academic institution confirming that the applicant is actively enrolled in the institution and will be conducting noncommercial academic research in Iran.  The applicant must also supply documentation of the research affiliation at an Iranian university to support compliance with the terms of Iran General License G.

Non-US Citizens at non-US institutions:

The Foundation will apply to OFAC for a license if the applicant's Wenner-Gren application is successful at Stage One of the Foundation's screening process. By submitting an application to the Foundation, the applicant is giving the Foundation permission to apply for an OFAC license. Funds cannot be disbursed by the Foundation without receipt of the license or a letter from OFAC stating that a license is not necessary. 

Research carried out in North Korea, Syria, or Crimea (including Sevastopol)

US citizens based at US or non-US institutions and non-US Citizens based at US institutions:

The applicant, whether a doctoral student or Post-Ph.D. scholar, must apply directly to OFAC for a license to carry out the specific research project proposed to the Foundation or for an interpretive letter stating that no license is required. If the project contemplates the purchase of goods or services in North Korea, or the exportation of goods or services from any country to Syria, North Korea, or Crimea (other than goods or services necessary and incidental to travel or personal maintenance), that fact must be specifically noted in the application to OFAC. Funds cannot be disbursed by the Foundation without receipt of the license or a letter from OFAC stating that a license is not necessary.

If equipment or other merchandise is being exported to Syria, North Korea, or Crimea, a license from the US Commerce Department Bureau of Industry and Security (BIS) may also be required. A special validation from the US Department of State may be required for travel to North Korea on a US passport.

Non-US Citizens at non-US institutions.

The Foundation will apply to OFAC for a license if the applicant's Wenner-Gren application is successful at Stage One of the Foundation's screening process. By submitting an application to the Foundation, the applicant is giving the Foundation permission to apply for an OFAC license. Funds cannot be disbursed by the Foundation without receipt of the license or a letter from OFAC stating that a license is not necessary. If equipment or other merchandise of US origin is being exported to Syria, North Korea, or Crimea, the Foundation may also need to obtain a license from the US Commerce Department Bureau of Industry and Security (BIS) prior to the disbursement of grant funds.

 

Research carried out in Venezuela

US citizens based at US or non-US institutions and non-US Citizens based at US institutions:

US law prohibits US persons from dealing with the Venezuelan government, including local governmental authorities and government-owned companies, except as authorized by OFAC.  OFAC has issued a number of general licenses that create exceptions to this rule.  For example, Venezuela General License No. 32, available here, authorizes US persons living in Venezuela to engage in transactions with the Government of Venezuela in connection with housing expenses and other personal living expenses.  Venezuela General License No. 10A, available here, authorizes US persons to purchase fuel in Venezuela from PdVSA or its subsidiaries for personal, commercial or humanitarian use.  Venezuela General License No. 35, available here, authorizes US persons to pay taxes, fees, and import duties to, and purchase or receive permits, licenses, registrations, certifications, and public utility services from, the Government of Venezuela, necessary for day-to-day operations.  Note, however, that anyone relying on General License No. 35 is required to file a report with OFAC by February 10 and August 10 of each year. 

For research carried out in Venezuela, the applicant must certify that  he/she will not engage in any transactions with the Government of Venezuela (including its local governments and entities it owns or controls), except as authorized by an OFAC general license, and will comply with any reporting requirements set forth in the applicable general license. 

If this representation cannot be made, the applicant must apply directly to OFAC for a license to carry out the specific research project proposed to the Foundation or for an interpretive letter stating that no license is required. In this situation funds cannot be disbursed by the Foundation without receipt of the license or a letter from OFAC stating that a license is not necessary.

Non-US Citizens at non-US institutions.

For research carried out in Venezuela, the applicant must agree to in writing that none of the grant funds will be used to make any payments of any kind to the Government of Venezuela (including local governments and entities it owns or controls). 

If this representation cannot be made, the Foundation will apply to OFAC for a license if the applicant's Wenner-Gren application is successful at Stage One of the Foundation's screening process. By submitting an application to the Foundation, the applicant is giving the Foundation permission to apply for an OFAC license. Funds cannot be disbursed by the Foundation without receipt of the license or a letter from OFAC stating that a license is not necessary.