Statement of Purpose
The Office of Foreign Assets Control ("OFAC") of the U.S. Department of the Treasury administers and enforces economic and trade sanctions based on U.S. foreign policy and national security goals against targeted foreign countries and regimes, terrorists, narcotics traffickers, those engaged in activities related to the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or economy of the United States. As part of its enforcement efforts, OFAC publishes a list of individuals and companies owned or controlled by, or acting for or on behalf of, targeted countries or organizations. It also lists individuals, groups, and entities, such as terrorists and narcotics traffickers, designated under programs that are not country specific. Collectively, such individuals and entities are called "Specially Designated Nationals" or "SDNs." Their assets are blocked, and U.S. Persons are generally prohibited from dealing with them without a specific license. Thus, the U.S. Government recommends that individuals and entities that intend to conduct business with non-U.S. individuals or organizations check the name of the individual or the organization against the SDN List.
Entities Affected by this Policy
All UNLV units are affected by this policy.
Who Should Read this Policy
All UNLV employees must read and understand this policy.
Policy
As host to international researchers and students, the University of Nevada Las Vegas hires individuals, provides educational and other services broadly to U.S and non-U.S. individuals alike, conducts research outside of the U.S., hosts international meetings, workshops and conferences, and is engaged in a spectrum of international activities. This includes, but is not limited to:
- The purchase of equipment or services from a foreign corporation;
- Enrolling foreign nationals in:
- professional or continuing education courses;
- on-line courses or executive programs; or
- otherwise providing services to or receiving funds from foreign nationals;
- Conducting international research collaborations
It is important to note that U.S. economic and trade sanctions may apply to both the provision of services to foreign nationals as well as financial transactions. Therefore, it is necessary to understand when and how to screen such individuals against the SDN list. Such screens may be conducted by the UNLV Export Control Officer through the use of the Visual Compliance on-line platform.
If the Export Control Officer’s Visual Compliance search comes back with positive results, the individual or entity will be informed that the transaction cannot be completed. The U.S. government prohibits transactions with persons and entities designated as Specially Designated Nationals that are included on an SDN list maintained by OFAC. The University is prohibited from employing, receiving funds from, engaging in any transaction with, or facilitating, aiding or otherwise supporting any activities of an individual, entity or organization on the SDN List.
Contacts
Definitions
- OFAC
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Office of Foreign Assets Control
- SDN
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Specially Designated Nationals
- Visual Compliance
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A password protected, web-based, export compliance tool that integrates multiple export control regulatory requirements into one automated system. The platform may be used to conduct Restricted Party Screenings (RPS) and Specially Designated Nationals (SDN) Screenings. These lists are updated regularly and include all government lists.
- Foreign National
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The term "foreign national" refers to everyone other than a U.S. citizen, a permanent resident alien, and certain "protected individuals" (refugees and those with asylum); it includes any company not incorporated in the United States.