Countries of Concern

If you are planning to work with any of these countries, please contact the Export Compliance office for guidance:

export@vumc.org
(615) 875-7577

Tier 1: Top Countries of Concern

Contact the Export Compliance office immediately when travel to, hiring of, visitors from, funding to or from, involving research or projects to or with, or physical exports to any of the following 4 main countries of concern ("T4") could occur:

Tier 2: Significant Risk Countries

Contact the Export Compliance office immediately when travel to, hiring of, visitors from, funding to or from, involving research or projects to or with, or physical exports to any of the following could occur:

Tier 3:

Countries with Strict Licensing Standards

For the export and/or 'deemed export' of certain controlled articles and services, the countries below necessitate a more thorough review for potential required U.S. Government export licensing:

AfghanistanIran*Qatar
ArmeniaIraqRussia*
AzerbaijanIsraelSaudi Arabia
BahrainJordanSomalia
Belarus*KazakhstanSouth Sudan
Burma (Myanmar)KuwaitSudan; (Republic of), (North)
CambodiaKyrgyzstanSyria*
Central African RepublicLaosTaiwan
China (PRC)LebanonTajikistan
Congo, Democratic Republic ofLibyaTurkmenistan
Cuba*MacauUkraine*
CyprusMoldovaUnited Arab Emirates (UAE)
EgyptMongoliaUzbekistan
EritreaNicaraguaVenezuela*
EthiopiaNorth Korea*Vietnam
GeorgiaOmanYemen
HaitiPakistanZimbabwe

Countries with OFAC Sanctions

From an economic and trade sanctions, foreign policy, and/or national security perspective, the countries below necessitate a more thorough review for potential required U.S. Government export licensing:

AfghanistanIran*Sudan; (Republic of), (North)
BalkansIraqSyria*
Belarus*LebanonUkraine*
Burma (Myanmar)LibyaVenezuela*
Central African RepublicMaliWest Bank (Palestine)
ChinaNicaraguaYemen
Congo, Democratic Republic ofNorth Korea* 
Cuba*Russia* 
EthiopiaSomalia 
Hong KongSouth Sudan 

 

Countries with Foreign Talent Recruitment Programs

VUMC is required to maintain a policy on Foreign Talent Recruitment. The VUMC Office of Research (OOR) administers the policy and its requirements.

Per 15 CFR 231.102 to 104 and 10 USC 4872(d)(2), the following four countries are considered "covered nations" which may be prohibited from certain transactions, research, and/or licensing:

  • China
  • Russia
  • North Korea
  • Iran

The U.S. Government-published rules directing the oversight of this policy were enacted through a combination of regulations and memorandums, specifically the NSPM-33 and Chips & Science Act of 2022.

For more information about the restrictions that may be applicable to interactions with these nations, please visit https://www.vumc.org/oor/ftrps or connect with ResearchSecurity@vumc.org.

 

 

The Federal Register (FR), published by the National Archives and Records Administration (NARA), is the official daily publication for rules, proposed rules, and notices from Federal agencies and organizations, as well as executive orders and other presidential/administrative document releases.

The links below reference the FR updates to the applicable sections of the regulations dealing with export control measures.

FR for State Department (ITAR)
FR for Commerce Department (EAR)
FR for Treasury Department (OFAC)

  • Consult the Federal Register (FR) regularly to ensure up-to-date awareness of these country policies.
  • The country lists above are accurate as of Dec 3, 2024. Lists subject to change daily.