Resource Explorer

For the purpose of research, it is advisable to follow University of Virginia and University of Virginia Health System policy as it pertains to research data management systems, external systems access, collaboration, and data sharing with certain regions of the world.

The U.S. Department of the Treasury, through its Office of Foreign Assets Control (OFAC), enforces U.S. embargo and sanction programs that restrict transactions with certain foreign countries.

UVA & UVA Health System has policies limiting Research collaboration with regions in the world that are defined by the U.S. Department of Treasury as restricted. As of January of 2023, the countries subject to a comprehensive or near comprehensive program of sanctions include the following:

• Cuba
• Iran
• North Korea
• Syria

• Russia (near comprehensive program of sanctions)

• Crimea region of Ukraine (near comprehensive program of sanctions)

• Donetsk region of Ukraine (near comprehensive program of sanctions)
• Luhansk region of Ukraine (near comprehensive program of sanctions)

Referenced below is University of Virginia and University of Virginia Health system policy associated with Restricted Countries.

1. This is the University of Virginia policy related to import/export controls, and is used as the basis for the country restrictions in place on any information system connected to electronic health records:

• FIN-043: Managing Export and Sanction Compliance in Support of University Activities - 5. Sanctioned Countries

1. A much more general acceptable use policy dictates some of the protections in place for network blocks:

• Policy IT-002 : Use of Electronic Information and Systems

Additional Resources:

• For your reference please go to the U.S. Department of Treasury website for a full list of Sanctions Programs and Country Information:

• https://ofac.treasury.gov/sanctions-programs-and-country-information

• The Code of Federal Regulations (CFR) annual edition is the codification of the general and permanent rules published in the Federal Register by the departments and agencies of the Federal Government produced by the Office of the Federal Register (OFR) and the Government Publishing Office.

• https://www.ecfr.gov/current/title-31#03

For more information, please contact the respective policy groups.