ASNT must comply with all applicable sanction laws when providing goods or services to individuals residing in an embargoed or sanctioned country. This includes those from the U.S. living abroad in these sanctioned or embargoed countries and providing goods or services to these individuals “ordinarily resident in” an embargoed or sanctioned country.1
The Department of Treasury, Office of Foreign Assets Control (OFAC) broadly regulates and restricts transactions with embargoed or sanctioned countries. This includes, but is not limited to, ASNT services2 and programs, academic collaborations, exchange of research materials and equipment. The most comprehensive controls apply to Cuba, Iran, North Korea, Crimea (Ukraine), Russia, and Syria. This means that as a general rule ASNT may not provide goods or services to residents within these countries absent OFAC authorization.
ASNT may not provide goods or services in any way to individuals or entities identified on OFAC’s Specially Designated Nationals and Blocked Persons List, also known as the SDN List. You can view the searchable database here: https://home.treasury.gov/policy-issues/financial-sanctions/specially-designated-nationals-and-blocked-persons-list-sdn-human-readable-lists. OFAC’s website provides information about its sanctions program, including sanctions brochures, advisories, and Frequently Asked Questions can be found at: http://www.treasury.gov/resource-center/sanctions/Programs/pages/iran.aspx
For any questions regarding ASNT sanctions for embargoed countries, please contact Customer Support at (614) 274-6003, (800) 222-2768 or email at email@example.com.
1Under US law, "Ordinarily Resident In" generally includes:
2 “Services” is generally interpreted to mean providing anything of value, even if no money is exchanged. Examples include but are not limited to: