Office of Research Integrity and Assurance

Sanctioned Countries and Regions

The following information will provide guidance if you are considering travel, engagement or collaboration with individuals and organizations with ties to countries and regions subject to U.S. comprehensive economic sanctions. These are currently Cuba, Iran, North Korea, and the Crimea, Donetsk (DNR), and Luhansk (LNR) regions of Ukraine.

There are many risks and considerations when working with sanctioned and embargoed countries and regions, and their nationals. Traveling, inviting visitors, collaborations, teaching, research, providing services, exporting, transferring or even the hand-carry of items can be strictly prohibited, and/or may require a U.S. Government authorization in the form of a license. These licenses can take a significant amount of time to request and may not be approved.

Contact [email protected] as soon as you are considering any activities or interactions with sanctioned countries or regions.

International Travel

Generally, travel to comprehensively sanctioned countries or regions has significant restrictions. These regulations are extremely complicated and require careful planning and analysis. Well in advance of any proposed travel please contact [email protected] with the nature of the trip, who you plan to collaborate or interact with (both individuals and organizations), and any Mason equipment you may be traveling with. We will review the matter, determine if a license may be required, and request it if needed. See our International Travel page for other travel requirements.

Also, under Mason’s Export Control and Sanctions Policy, all trips to comprehensively sanctioned countries and regions require prior approval through the “Application for Travel to Hazardous Areas and Countries Under Comprehensive Economic Sanctions”.  Please review the International Travel Website for more information or contact [email protected].

Those approved to travel to sanctioned countries or regions will be enrolled and must complete appropriate training in advance of their trip.

Traveling with Mason laptops, equipment or items:
If you plan to travel to a comprehensively sanctioned country or region with a Mason laptop or equipment you will need prior Mason approval, an export license will likely be required – and in some cases, a federal filing is also required in advance of travel. See our Forms page to request to travel with a Mason laptop or equipment. If a license is required, these can take a lot of time to receive and may not be granted. See our FAQ below for additional information and for Cuba specific guidance.

Personal travel or traveling with personal laptops and equipment: If you are traveling to a sanctioned country for purely personal reasons, you must still contact [email protected] if you wish to work on Mason projects while there or take Mason laptops or equipment. In some cases, personally-owned laptops and equipment are authorized under a general license. Travelers can also take publicly available information such as textbooks and publications, magazines, and other. Contact [email protected] for what is permissible.

Note that there is no VPN or other remote access into the university local network while in a sanctioned country or region. See our FAQs below for more information about DUO restrictions.

If you plan to ship, export or hand-carry equipment or items to a comprehensively sanctioned country or region, an export license will likely be required. Please reach out to us well in advance of engaging in any export or shipment at [email protected] and see our International Shipments page for more detailed information. We will review and determine if an export license may be required, including the process and timeframe.

International Collaborations

Generally, international collaborations including research, fieldwork, teaching, presenting, consulting or co-publishing with individuals or entities with ties to comprehensively sanctioned countries or regions, has significant restrictions and requires a U.S government license, even if the topic is non-technical. Contact [email protected] to review your proposed collaboration for prior approval.

In general, there are restrictions and limitations depending on the country involved:

  •  Iran: A license from the U.S. Government is almost always required if you want to collaborate with colleagues in Iran.
  • Cuba: License requirements vary and require proper review and documentation.

Lastly, you will need to be enrolled and complete appropriate training prior to the international collaboration.

Conferences, Meetings or Events

Generally, you will need a license from the U.S. Government if you wish to present a paper in a sanctioned country, answer questions on that paper, or, in some cases, even simply attend a conference there, even if the topic is non-technical. When presenting or sharing data or information in an international setting (including in the U.S. where the audience may include foreign nationals), you must limit your presentation to information or data that is published, or is publicly available, or that qualifies as Fundamental Research*. Do not include or discuss any proprietary, unpublishable, or export-controlled data or information as that may constitute an unauthorized export. Contact [email protected] for guidance.

*Note: If you attend or present in a non-sanctioned country, where nationals from sanctioned countries may attend, or if you wish to attend or present in your own personal capacity on material that is not related to your Mason research, then you would not need a license. You may also share a copy of a paper you have presented to individuals in sanctioned countries, but you cannot respond to questions on the paper without a license from the U.S. Government. See our FAQ for specific examples and more information.

Restricted Party Screening

We will need to screen any international collaborator, partner, entity or recipient of items, information or services to ensure they are not sanctioned, prohibited or blocked individual or entity. See the Restricted Party Screening page for more information.

Working with Students

There are a number of considerations when working with students with ties to sanctioned countries.

Assignments: Mason students are permitted to take publicly available materials such as publications or textbooks with them while they are travelling outside the U.S. and use those materials to complete academic course work. They are also permitted to take personal laptops and electronics, but not Mason owned equipment. However, if a student is travelling to a sanctioned country or region:

  • they cannot conduct Mason related research
  • participate in online classes
  • work for Mason, including as a GTA or GRA

Communications: Mason students can communicate with their instructors or advisors while in a sanctioned country or region using their GMU email account. However, such communications may only relate to publicly available information, such as course schedules and other logistical questions. Students can access Canvas, Patriot Web, and the library’s online resources, but will not have VPN or other remote access into the university network from sanctioned countries. Communications related to publishing between faculty and students located in sanctioned countries may be permissible, but you must notify [email protected] first so that we can confirm this engagement meets certain requirements.

Student presentations: Students can generally not present on their research at the invitation of a university in a sanctioned country without a license from the U.S. Government, as participating would be considered a service to that university. If the student publishes papers related to their research, they can direct the university to those publicly available papers but cannot answer any questions related to these without a license.
See our FAQ below for additional examples.

All students from sanctioned countries and their faculty advisors will be enrolled in annual training regarding the sanctions regulations to help them understand the requirements and regulations.

Frequently Asked Questions

It depends. You may need a license from the U.S. Government to collaborate with colleagues in a sanctioned country or region depending on which country/region is involved: Publishing activities would not be permitted without a license from the U.S. Government, however, if the colleague is associated with their country’s government and is acting in their official capacity. The U.S. sanctions laws do not consider academic and research institutions to be part of the government, so publishing activities with people working at such institutions are allowed.
  • A license from the U.S. Government is almost always required if you want to collaborate with colleagues in Iran.
  • If you wish to collaborate with colleagues in Cuba on non-commercial research, then you would not need a license, but certain requirements must be met. Contact [email protected] before beginning collaborations with individuals in Cuba for review and determination, and to ensure proper records.
  • Licenses from the U.S. Government can take months, please contact us at [email protected] as soon as you decide to pursue a collaboration.
It depends. For example, if the colleague is returning to Iran, then a license from the U.S. Government would be required to continue collaborations once the colleague leaves the U.S. Since licenses from the US Government can take months, please contact us at [email protected] as soon as you decide to continue a collaboration.
It depends. Contact [email protected] for a review of the circumstances. For example:
  • Some activities related to publishing are permitted, but we must meet the requirements in the sanctions regulations and document the requirements were met. For example, if you are clearly in the process of publishing something with a colleague in Cuba or Iran, then you do not need a license to engage in activities necessary to publish, such as communicating with your colleagues regarding the publication, editing the document, or adding items that enhance the work like photos, explanatory text, or search capabilities in electronic publications.
  • If the colleague is associated with their country’s government and is acting in their official capacity, then publishing activities would not be permitted without a license from the U.S. Government. However, U.S. sanctions laws do not consider academic and research institutions to be part of the government, so publishing activities with people working at such institutions are allowed.
  • Contact our office at [email protected] so that we can determine if you meet the requirements and to help you maintain proper records of the activity.
No, unless you get a license from the U.S. Government because serving as a reviewer would be considered a service to the journal.
Yes, peer review is permitted if you are simply determining whether or not to select for publication an article as submitted. Thus, you can review an article even if you know or suspect that the author is from a sanctioned country.
No, unless you get a license from the U.S. Government, because participating in an interview would be considered a service to the newspaper/website. You can direct them to publicly available information, such as your webpage or Mason’s website.
Yes. Students are permitted to take publicly available materials such as publications or textbooks with them while they are travelling outside the U.S. and use those materials to complete academic course work. However, if a student is travelling to a sanctioned country, they cannot conduct Mason related research, participate in online classes, or work for Mason in any capacity (ex. as a GTA or GRA) while in that country.
It depends on the communication. Students will still have access to their GMU email account while in a sanctioned country and may use this to exchange emails with instructors or advisors at Mason. However, such communications may only relate to publicly available information, such as course schedules and other logistical questions. Students can access Canvas, Patriot Web, and the library’s online resources, but will not have VPN or other remote access into the university network from sanctioned countries. Communications that are related to publishing between faculty and students located in sanctioned countries may also be permissible, but you must notify [email protected] so that we can confirm this meets the regulatory requirements.
You can share publicly available information with individuals from sanctioned countries, so if you are providing them with information that is on the Mason website, for example, or if you are directing them to the website, that is permissible under the regulations. If there are specific questions that you frequently receive from prospective students, you could post that information to your department website (or your personal page on the website) and then direct students there.
No, unless you get a license from the U.S. Government, because participating would be considered a service to the university. If you publish any papers related to your research, you can direct the university to these publicly available papers. You can also direct them to other publicly available information, such as Mason’s website. Please note that you cannot answer any questions related to your published papers without a license.
In general, the answer is no, you cannot take Mason owned laptops or equipment to a sanctioned country without a license from the U.S. Government. If you wish to take a Mason laptop to Cuba, send an email to [email protected]. There is specific documentation that must be filed with the U.S. Government in order to take a Mason laptop to Cuba, and our office can file that paperwork on your behalf. Travelers can take personal laptops to sanctioned countries.
If you wish to travel to a sanctioned country or region on behalf of Mason, you must contact our office at [email protected]. We need to preapprove all Mason travel to sanctioned countries to determine if we need a license from the U.S. Government. In addition, you'll need to submit an Application for Travel to Hazardous Areas and Countries that will be approved by UTAC. If your travel is approved, you can take publicly available information with you, such as textbooks or other publications, and also personal belongings, such as your cell phone and personal laptop. In general, you cannot take a Mason-issued laptop to a sanctioned country, regardless of the reason for travel unless you get a license from the U.S. Government. Unfortunately, these licenses take a lot of time to receive, and they often are not granted by the U.S. government. Note on travel to Cuba: In almost all cases, travel to Cuba requires a general or specific license from the U.S. Department of Treasury. A general license is in place that allows travel to Cuba for some research activities and/or for attendance at an international conference under certain conditions, with a letter from Mason describing your activities and your professional association with the University. If your travel plans include transit to or through Cuba, contact [email protected] for assistance in determining if your travel qualifies under a general license. Under certain, limited conditions it is permissible to take a Mason laptop to Cuba, but you need to coordinate with our office as there are Federal filing requirements that must be met in advance of travel. There is no VPN, DUO or other remote access into the university local network while in a sanctioned country. You can still use your GMU email while in a sanctioned country and the library’s online resources. If you are traveling to a sanctioned country for purely personal reasons, then you do not need to talk to our office unless:
  • You wish to take Mason equipment with you, as that will require Mason to apply for a license from the U.S. Government, or
  • You wish to work on Mason-related projects while they are there because we will need to determine if a license is needed.
You will need a license from the U.S. Government if you wish to present a paper in a sanctioned country, answer questions regarding that paper, or, in some cases, even simply attend a conference there. This applies if you are attending or presenting on behalf of Mason. If you wish to attend or present at a conference in your own personal capacity on material that is not related to your Mason research, then you would not need a license from the U.S. Government. If you attend or present at a conference in a non-sanctioned country, but you know that nationals from sanctioned countries may attend, you do not need a license from the U.S. Government. You can send a copy of a paper you have presented to individuals in sanctioned countries. However, if the person who requests the paper asks you questions regarding it, you cannot respond without a license from the U.S. Government. You can publish a list of Frequently Asked Questions regarding the paper and direct people to those for more information.
If you are traveling to a sanctioned country or region for purely personal reasons, you must still contact [email protected] if you wish to take Mason equipment with you, or you wish to work on Mason-related projects while they are there. In both scenarios we will need to determine if a license is needed.
Yes, but please ensure that the information you are sharing is not subject to any restrictions or export controls.
No. Effective May 5, 2022, DUO blocks access to its service when it is accessed from countries or regions subject to U.S. economic sanctions. These are the countries/regions where DUO restricts access (notice that this list includes Sudan which is no longer a comprehensively sanctioned country):
  • Cuba
  • North Korea
  • Iran
  • Sudan
  • Syria
  • Ukraine - regions including:
    • Crimea region
    • Donetsk region
    • Luhansk region
    • Sevastopol region
Once DUO blocks service, users in these regions will see a DUO error message: "Access denied. DUO Security does not provide services in your current location." With DUO now required for access to Blackboard and Patriot Web (and any other University service that requires DUO authentication), individuals who travel to these countries/regions will not be able to use these services after May 5, 2022. If you are a student or faculty member who may be affected by DUO's blocking policy, please be aware of this issue if you intend to travel home and take appropriate actions before departing.
Contact us

If you have questions regarding exports and sanctions compliance, think that your work or project may involve export controls, or suspect an export violation, please contact [email protected].

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