The U.S. Department of the Treasury's Office of Foreign Asset Control (OFAC) has established regulations that prohibit U.S. persons (including the University of California) from providing services - including remote educational services - to individuals in certain sanctioned countries without a general or specific license. The list of OFAC sanctioned countries currently includes: Cuba, Iran, North Korea, Syria and the Ukraine-Crimea Region
In order to avoid violating that law, UC Berkeley is taking reasonable steps to ensure that we are not delivering remote educational services to, hiring, or shipping export controlled equipment or software to individuals in those countries without a US export license. Going forward, the campus will require affected students to certify that they are not enrolled, and will not remain enrolled in UC Berkeley classes while outside the U.S.; this certification will be managed by the Berkeley International Office (BIO).
Additional requirements: In addition to the OFAC license requirements that apply to providing remote educational services, other potential licensing requirements may apply, depending on the nature of the intended activity and the country. For example:
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A license will likely be required to export any items (e.g., laptops, software, other equipment) or controlled technical information to individuals located in sanctioned countries.
Note that a license may also be required to export items (e.g., software, other equipment) or controlled technical information to any individual in any country outside the U.S. - including countries that are not on the sanctioned countries list. The campus Export Control Officer (ECO) should be consulted about any such proposed activities, and can assist in applying for licenses for the university where needed.
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Regardless of the context (i.e., not just in the context of remote education), a license will likely be required for any transaction outside the U.S involving individuals with citizenship from a sanctioned country (e.g., remote work arrangements, where an individual from a sanctioned country may be conducting work or research for the UC outside the U.S.). The campus ECO should be consulted about any such proposed activities, and can assist in applying for licenses for the university where needed.
In the future, we ask any individual who plans to be located in a sanctioned country to contact the Export Control Officer at ec-team@berkeley.edu as soon as possible.