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Information for Grantees Conducting Research in OFAC Sanctioned Countries

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, and Crimea (including Sevastopol).

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 at http://www.treasury.gov/resource-center/sanctions/Pages/licensing/aspx. The appropriate OFAC licensing category for Wenner-Gren grants is "transactional."

For individuals based at US institutions, all grants involving research carried out in Iran, North Korea, Syria, or Crimea (including Sevastopol) are paid to the applicant's institution and not the individual. The institution is the grantee of record and is required to sign the grant agreement. For the terms contained in the grant agreement see Requirements and Conditions of the specific grant program to which you are applying.

Compliance with the US Government country 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.

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 OFAC website at https://www.ecfr.gov/cgi-bin/text-idx?node=se31.3.515_1564. 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 OFAC website at https://www.ecfr.gov/cgi-bin/text-idx?node=se31.3.515_1564. 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 at https://www.state.gov/e/eb/tfs/spi/cuba/cubarestrictedlist/275331.htm
  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 at http://www.bis.doc.gov/index.php/policy-guidance/country-guidance or the export compliance office at your institution.

For more information on the Cuba OFAC sanction program, please consult the US Treasury Department website at: www.treasury.gov/resource-center/sanctions/Programs/pages/cuba.aspx

Research carried out in Iran, 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, or his/her institution 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 North Korea, or the exportation of goods or services from any country to Iran, Syria, 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 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.

For more information on the OFAC sanctions programs, please consult the US Department of Treasury website at: www.treasury.gov/resource-center/sanctions/Programs/Pages/Programs.aspxFor information on Export Administration Regulations, please consult the US Commerce Department Bureau of Industry and Security (BIS) website at: http://www.bis.doc.gov/index.php/policy-guidance/country-guidance