Sanctioned and Embargoed Countries

Guidance on engaging with countries subject to federal restrictions.


Engaging with Sanctioned and Embargoed Countries

The Department of Treasury, Office of Foreign Assets Control (OFAC), broadly regulates and restricts transactions with sanctioned and embargoed countries, including academic exchanges and research collaborations. With the exception of Cuba, U.S. citizens are free to travel to all countries without obtaining a license from OFAC; however, certain activities within, or with citizens of, various countries may require a license.

OFAC regulations apply to U.S. persons, which are defined as any U.S. citizen, permanent resident alien, entity organized under the laws of the United States, or any person in the United States. The regulations apply to U.S. citizens and permanent residents wherever located, and to foreign nationals located inside the United States. Individuals with dual U.S. citizenship are considered “U.S. persons.”

Failure to comply with sanctions regulations can result in severe consequences for both the University of Pennsylvania as well as the individual involved, including fines of up to $1,000,000 and/or up to 20 years in prison.

Currently, some of the most comprehensive controls apply to Cuba, Iran, North Korea, and Syria.

Note: Travel to North Korea is highly restricted and requires special validation from the U.S. State Department. No exemptions for academic activities currently exist.

Please be advised that to comply with U.S. regulations, DUO, Penn's multi-factor authentication tool, blocks authentications from users whose IP address originates in certain countries and regions. Penn faculty, staff, and students based in or traveling to the following areas will be unable to authenticate PennKey and other DUO-protected applications:

  • Cuba
  • Iran
  • North Korea
  • Sudan
  • Syria
  • Crimea, Sevastopol, Donetsk, and Luhansk regions of Ukraine

Due to regulatory restrictions, there is currently no recommended alternatives to access PennKey-protected sites from these regions. Travelers should be aware that IT resources will be limited and discuss with their School/Department/Center to determine what accommodations can be made ahead of time.

Anyone acting in their capacity as a Penn faculty member, employee, or student, regardless of nationality or passport used, is subject to the OFAC regulations and may require a license from the U.S. government before engaging in certain activities in, or with, comprehensively sanctioned countries. Always consult the Office of Export Compliance before traveling to or engaging with individuals in an embargoed or sanctioned country.

Travel Restrictions and Countries of Concern Memo from the Senior Vice Provost for Research concerning Iran-related U.S. Sanctions Regulations Iran Sanctions: FAQs

Cuba Sanctions

Important information for Penn-related Cuba activities and travel

Iran Sanctions

Important information for Penn-related Iran activities and travel

Russia-related Sanctions and Export Restrictions