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Information for Grantees Conducting Research in OFAC Sanctioned Countries

January 28, 2015

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, Sudan and Syria.

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 Cuba, Iran, North Korea, Sudan or Syria 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:

US citizens based at US or non-US institutions and non-US citizens based at US institutions.

Funds cannot be disbursed by the Foundation without the following:

  1. For Doctoral Students
    • The student must supply a signed statement from the institution (if the applicant is based at a US institution) or from the applicant (if the applicant is based at a non-US institution), stating that 1) the individual is a student currently enrolled in a graduate degree program, and 2) the individual's research in Cuba is for the purpose of obtaining that degree.
  2. 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 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 institution (if the applicant is based at a US institution) or from the applicant (if he/she is based at a non-US institution or is an independent scholar) stating that the scholar 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 that an individual does not qualify under the general license, the post-Ph.D. scholar or his/her institution must apply directly to OFAC for an appropriate license and supply a copy to the Foundation.
  3. All US academic institution grantees must also confirm compliance with Export Administration Regulations governed by the US Commerce Department Bureau of Industry and Security (BIS). For more information on the regulations please consult the BIS website at: http://www.bis.doc.gov/index.php/policy-guidance/country-guidance

Non-US citizens at non-US institutions

Funds cannot be disbursed by the Foundation without the following:

  • Doctoral students and 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 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 individual 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 that the doctoral student or Post Ph.D. scholar does not qualify under the general license, 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 this situation applies.

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, Sudan or Syria:

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 contemplate