Economic Sanctions and Restricted Parties

Certain entities and individuals are subject to sanctions or other restrictions under U.S. law.  These restrictions apply to both domestic and foreign entities and individuals and may restrict your ability to engage in a project, collaboration or other transaction with that entity or individual.  Columbia’s online screening tool, Visual Compliance, allows you to quickly determine whether an entity or individual is listed on a Restricted Party List.  If you are considering entering into a transaction with an entity or individual listed on a Restricted Party List, immediately contact Research Compliance and Training.

For information regarding opening a Visual Compliance account, please contact Research Compliance and Training.

Economic Sanctions and Restricted Parties Topics

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OFAC Sanctions Programs

The U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) maintains sanctions against certain countries, industries, entities and individuals.  Certain countries are subject to comprehensive sanctions, while others are subject to targeted sanctions.  Comprehensive sanctions prohibit transactions with a country’s government and virtually all other transactions, including exports/imports, involving the sanctioned country.  Targeted sanctions prohibit transactions with specified industries, entities, or individuals listed on OFAC’s Specially Designated Nationals and Blocked Parties List or Consolidated Sanctions List (collectively, “SDNs”).  Columbia University and its personnel are prohibited from engaging in transactions with SDNs without prior government authorization to do so. 

Comprehensive sanctions: 

*Russia is subject to increasingly broad sanctions

Targeted sanctions: 

Although restrictions vary among sanctions programs, the following transactions are generally prohibited without an OFAC license -

  • entering into contracts, agreements or research collaborations with SDNs
  • making payments to or receiving payments from SDNs
  • providing services / training to or receiving services / training from SDNs.

In addition to the above, exporting or importing items, information, or software to or from a sanctioned country may require a license from OFAC, the Commerce Department’s Bureau of Industry and Security, or both.

If you propose to engage in any sort of transaction involving a country subject to either comprehensive or targeted sanctions, please contact Research Compliance and Training.

Failure to comply with U.S. sanctions regulations may result in substantial penalties.  Criminal penalties for willful violations can include fines ranging up to $20 million and imprisonment of up to 30 years.  Civil penalties for violations can include fines ranging up to $1,075,000 for each violation.

For a complete list of OFAC’s current sanctions programs, see OFAC’s Sanctions Program and Country Summaries website.

Other U.S. Restricted Party Lists

In addition to OFAC, other U.S. Government Agencies maintain Restricted Party Lists.  Entities and individuals who appear on these lists are “restricted parties” and certain transactions with these restricted parties are prohibited.  It is important to check these Restricted Party Lists prior to engaging in a transaction.  Columbia University and its personnel are prohibited from engaging in certain transactions with restricted parties without prior government authorization to do so. 

Engaging in prohibited transactions with parties included on Restricted Party Lists can result in significant civil and criminal penalties, including fines, debarment, and imprisonment.  Columbia encourages faculty and staff to conduct restricted party screening on international collaborators prior to the start of activities.  Restricted party screenings can be done in two ways:

1. Request a restricted party screening: To request a restricted party screening, please send an email to Research Compliance & Training ([email protected]). For entities, please include the entity’s name and country.  For individuals, please include the individual’s name, current affiliation, and country. 

2. Open a Visual Compliance Account:  Visual Compliance is Columbia’s online restricted party screening tool and allows you to quickly determine whether an entity or individual appears on a Restricted Party List.   To open a Visual Compliance account, please send an email to Research Compliance & Training ([email protected]). RCT will send you instructions to register an account and will provide training. 

If the entity or individual with whom you intend to deal is a restricted party, contact Research Compliance & Training.

Restricted Party Screening using Visual Compliance

Columbia’s online screening tool, Visual Compliance, allows you to quickly determine whether an entity or individual appears on Restricted Party Lists. 

To open a Visual Compliance account or attend a Visual Compliance training (offered twice per month), please email RCT at [email protected]. 

The Guidance for Restricted Party Screening using Visual Compliance provides information on evaluating matches, dynamic screening alerts, and escalation procedures. The Incident Manager Guidance provides more information about using the Incident Manager portal in Visual Compliance.

Visual Compliance screens against many U.S. and International restricted party lists, including but not limited to the lists below:

If the entity or individual with whom you intend to deal is a restricted party, contact Research Compliance and Training.

NYS Executive Order 16 

New York State’s Executive Order 16 (EO 16) (Prohibiting State Agencies and Authorities from Contracting with Businesses Conducting Business in Russia) prohibits NYS agencies from contracting with entities “conducting business operations in Russia”, which is broadly defined in the EO and can capture research-related and academic activities.  NYS EO 16 restrictions are distinct from OFAC’s sanctions against Russia and must be evaluated separately.  For questions about NYS EO 16 and to request a compliance review, please contact Michelle Avallone, Director for Export Controls and International Engagements.

Prohibition on Certain Chinese Telecommunications and Video Surveillance Services or Equipment (NDAA 889)

Section 889 of the National Defense Authorization Act of 2019 prohibits federal agencies from entering into contracts, including sponsored research contracts, with an entity that uses “covered telecommunications equipment or services” as a “substantial or essential component of any system” or as “critical technology as part of any system”.  Section 889 also prohibits the use of federal loan or grant funds to procure or obtain covered telecommunications equipment or services.  These prohibitions went into effect on August 13, 2020. 

Section 889 also prohibits contractors from providing to the Government any equipment, system, or service that uses covered telecommunications equipment or services as a substantial or essential component of any system, or as critical technology as part of any system.  This prohibition went into effect on August 13, 2019.

“Covered telecommunications equipment or services” are:

  • Telecommunications equipment produced by Huawei Technologies Company, ZTE Corporation, or any subsidiary or affiliate of these entities;
  • Video surveillance technology and equipment used for certain public safety, physical surveillance, or national security purposes and produced by Hytera Communications Corporation, Hangzhou Hikvision Digital Technology Company, Dahua Technology Company, or any subsidiary or affiliate of these entities;
  • Telecommunications or video surveillance services provided by any of the above-named entities or using the above-described equipment; and
  • Telecommunications or video surveillance equipment or services of an entity that the U.S. Secretary of Defense reasonably believes to be owned or controlled by, or otherwise connected to, the government of the People’s Republic of China.

A list of the prohibited companies is available here.

A list of the prohibited companies’ subsidiaries and affiliates is available here (UNI login required).

For questions about NDAA Section 889, including questions about specific equipment or services, please contact Michelle Avallone, Director for Export Controls and International Engagements.

DoD Prohibited Entity Lists

The Department of Defense (DoD) has issued its 2026 DOD Risk Matrix describing how it will evaluate “undue foreign influence” risk factors when reviewing proposals for fundamental research, including collaborations and affiliations with entities on its "Prohibited Entity Lists". 

For more information about these risks, visit Foreign Talent Recruitment Programs (FTRPs) and Malign FTRPs.

Where to Go for Help

Contact Research Compliance and Training -

  • If a transaction/ project involves activities in a country subject to comprehensive or targeted sanctions
  • If a transaction/ project involves transactions with an entity or individual listed on OFAC’s SDN List, Consolidated Sanctions List, or other U.S. Restricted Party List
  • For questions regarding opening a Visual Compliance account or conducting restricted party screenings

Compliance Hotline

The Compliance Hotline is a confidential channel for employees to report or seek guidance on compliance issues. It is available to Columbia employees by telephone (866)-627-3768 and online at the Compliance Hotline Website with confidential report handling and the option for anonymous reporting. There is no tolerance for retaliation against those who report a compliance concern in good faith.