Common Questions and Answers - Cuba and Iran Sanctions

Here are answers to some common questions in connection with the Cuba and Iran OFAC sanctions as they may relate to the University of Rochester community:

Question
Can I host a visiting student or scholar from Cuba or Iran to the University?

Answer
Cuba: yes (see §515.571(a)(5); §515.571(e); §515.565(a)(v)), provided you coordinate with Global Engagement and the International Services Office

Iran: yes (see General License G (a), (b)(1); §560.505), provided you coordinate with Global Engagement and the International Services Office

Question
Can I share information with someone in Cuba or Iran?

Answer
Cuba: yes, provided the information falls within the definition of “Information and informational materials” (see §515.206(a); §515.332)

Iran: yes, provided the information falls within the definition of “Information and informational materials” (see §560.210; §560.315)

Question
Is there a default U.S. ban on travel to Cuba or Iran?

Answer
Cuba: yes. (see §515.201(b)(1)) (Note however that certain travel to Cuba is permitted under a few specific General Licenses)

Iran: no. (see §560.210(d)) (Note however that OFAC interprets prohibited “services to Iran” (see §560.204) quite broadly, so while travel to Iran may be permitted, your activities in Iran may be considered a “service” which requires a specific license from OFAC. For example, see question/answer below about participating in a conference in Iran)

Question
Can I participate in a professional conference in Cuba or Iran?

Answer
Cuba: yes, provided your travel complies with all of the requirements of §515.564(a)(2); §515.565(a)(vii).

Iran: default answer is “no”. Qualified answer “yes”, provided the University applies for and receives a specific license from OFAC prior to your travel (please contact the University’s Export Control Officer, Josef Mejido to apply for an OFAC license)

Question
Can I peer review an article from someone in Cuba or Iran?

Answer
Cuba: yes, provided the activities do not involve the Government of Cuba, and are in alignment with §515.577 Authorized transactions necessary and ordinarily incident to publishing. Note, the “Government of Cuba” does not include any academic and research institutions and their personnel.
If the peer review process for example is in connection with a sanctioned country government official, but only involves a preexisting, “camera ready” article, and such peer review is simply to determine whether or not to select the article for publication, then such activities are generally permitted. However, keep in mind that peer review that returns an article to the author with editorial comments or general suggestions or otherwise makes any substantive or artistic alteration is prohibited unless licensed (see OFAC’s Guidance on Certain Publishing Activities)

Iran: yes, provided the activities do not involve the Government of Iran, and are in alignment with §560.538 Authorized transactions necessary and ordinarily incident to publishing. Note, the “Government of Iran” does not include any academic and research institutions and their personnel.
If the peer review process for example is in connection with a sanctioned country government official, but only involves a preexisting, “camera ready” article, and such peer review is simply to determine whether or not to select the article for publication, then such activities are generally permitted. However, keep in mind that peer review that returns an article to the author with editorial comments or general suggestions or otherwise makes any substantive or artistic alteration is prohibited unless licensed (see OFAC’s Guidance on Certain Publishing Activities)

 

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