No, not necessarily. We are usually able to interact with citizens of sanctioned countries when they are lawfully working or studying with us in the United States, although there might still be certain subject matter that we cannot share with them without a license. There are typically more restrictions upon the interactions that we can have with citizens of sanctioned countries when they are in their home countries. Even so…
Some U.S. sanctions programs are more restrictive than others. Your project may involve a country that is subject to a sanctions program but one that does not restrict the kind of transactions into which you will need to enter with its organizations or people. For instance…
Iran is a comprehensively sanctioned country, and the regulations that embody the Iran sanctions program generally forbid any export/import of goods, services or technical know-how to/from that country. There are a few exceptions to this broadly restrictive policy towards Iran, but it is typically quite difficult (if not impossible) for us to involve Iranian entities and individuals in our research, technical assistance and educational activities, if they are not lawfully in the U.S., or if we are unable to procure a license from the Department of the Treasury’s Office of Foreign Assets Control.
Zimbabwe, on the other hand, is also a sanctioned country, but unlike the Iran sanctions program, the Zimbabwe sanctions program only targets certain entities and individuals and does so in such a limited way as to rarely prevent us from being able to pursue our professional goals in or with Zimbabwean organizations and individuals.
If your research project or other work will involve a sanctioned country, the Export Control Office can help you to determine whether any or all of your proposed activities are forbidden in the absence of a license. If a license is required, we can advise as to whether submitting a license application would be worthwhile, and if it is, we can assist with application drafting and submission.