The Entity List and Other U.S. Sanctions Lists

Guidance to Faculty and Principal Investigators Regarding International Activities

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What is the U.S. Commerce Department’s Entity List? May I collaborate with an individual or entity (e.g. a university or company) that is included on the Entity List?

U.S. export control laws generally restrict the export of technologies on a country-by-country basis.  In addition, the Entity List catalogs over 1,000 people and organizations throughout the world for which more stringent export control restrictions are imposed. This means that even if an item may typically be exported to a particular country, that same item may not be permitted to be exported to a recipient in that country that is listed on the Entity List. The export control team (exportcontrolhelp@mit.edu) can screen your potential collaborators against the Entity List and other pertinent government watch lists in advance, and advise you of related risks.

A fundamental research collaboration with an entity or individual on the Entity List is lawful, although there are restrictions on interactions and each such collaboration should be considered on a project-by-project basis, including through consultation with the export control team. Importantly, you must not ship or transfer any tangible physical items (this includes commercially-available goods as well as physical items that you create as part of research) to an Entity List institution. Also, except for publicly available information or the results of fundamental research, you generally may not furnish software, technical information, or research reports to an Entity List institution.

February 19, 2021

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What is the U.S. Treasury Department’s Specially Designated Nationals (SDN) list? May I collaborate with an individual or entity (e.g. a university or company) that is included on the SDN list?

You cannot collaborate or otherwise engage with an individual or entity on the SDN list unless you receive specific authorization from the export control team and a license from the U.S. government. The SDN list contains names of individuals and entities targeted for special sanctions by the U.S. government. These include terrorists, drug traffickers, and state-controlled entities of sanctioned governments, among others.

A license from the U.S. government to engage with an SDN is difficult to obtain and often requires several months of governmental review. If you have engaged with, or seek to engage with, someone on the SDN list, please contact exportcontrolhelp@mit.edu for further guidance. The export control team can also screen your potential collaborators against the SDN list and other pertinent government watch lists in advance, and advise you of related risks.

February 19, 2021

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