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Information for Grantees Conducting Research in OFAC Sanctioned Countries

October 28, 2014

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, Burma (Myanmar), 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
    US citizens or non-US citizens attending a US academic institution:
    • The student must supply a letter on official letterhead of the US academic institution, signed by a designated representative of the sponsoring US academic institution, stating that 1) the individual is a student currently enrolled in a graduate degree program at an accredited US academic institution, and 2) the individual's research in Cuba will be accepted for credit toward that degree.

    US citizens attending a non-US academic institution:

    • The student must apply directly to OFAC for a license and supply it to the Foundation.
  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 directly related to professional research in their professional areas, provided that their research 1) is of a noncommercial nature; 2) comprises a full work schedule in Cuba; and 3) has a substantial likelihood of public dissemination. 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:

  1. For Doctoral Students:
    • The Foundation will apply to OFAC for a license to disburse the funds, 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.
  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 directly related to professional research in their professional areas, provided that their research 1) is of a noncommercial nature; 2) comprises a full work schedule in Cuba; and 3) has a substantial likelihood of public dissemination. 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 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 contemplates the purchase of goods or services in Iran, or Sudan or the exportation of goods or services from any country to Iran, Sudan or Syria (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, a license from the US Commerce Department Bureau of Industry and Security (BIS) may also be required.

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, 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.aspx

For 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

 

Research carried out in Burma (Myanmar) and North Korea :

For all applicants, whether US citizens or not, and whether based in the US or not, the following applies.

Before the grant funds will be released, the Foundation requires a statement from the grantee representing that grant funds will not be used for any activity that violates: 

  • OFAC regulations including sanctions programs and the SDN List, and
  • where applicable, Export Administration Regulations governed by the US Commerce Department Bureau of Industry and Security (BIS).

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.aspx

For 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

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