Export Compliance Program

International Financial Transactions

The Treasury Department's Office of Foreign Assets Controls (OFAC) administers and enforces economic and trade sanctions based on US foreign policy and national security goal. Countries designated by OFAC as having trade sanctions imposed by the United States for reasons of anti-terrorism, non-proliferation, narcotics trafficking, or other reasons. Sanctions vary among the countries.

  • You must have a license to make payments to parties on the OFAC list. (Note the applying for and obtaining licenses must be requested through the Office of Export Control).
  • The recipient and institution must be screened on the Restricted Parties List

Prohibited transactions are trade or financial transactions and other dealings in which U.S. persons may not engage unless authorized by OFAC or expressly exempted by statute. Because each program is based on different foreign policy and national security goals, prohibitions may vary between programs.

There may be exceptions to the prohibitions. OFAC regulations often provide general licenses authorizing the performance of certain categories of transactions. OFAC also issues specific licenses on a case-by-case basis under certain limited situations and conditions.

The list of current sanctions programs can be found on the OFAC list; notably Crimea, Cuba, Iran, North Korea, Sudan, Syria, and Ukraine-related.

To ensure compliance with OFAC sanctions and other restricted transactions, IIT’s Procurement Department uses specialized export compliance software to check new vendors against various lists of restricted individuals and entities, and rechecks the vendor base on a regular basis to identify changes in status. IITs Accounts Payable Department checks non-vendor payees against the same set of restricted party lists.

Please contact the Office of Export Control if you should have any questions.