Countries of Concern

Generally speaking, a license may be required to ship or transfer “controlled” technology, data, hardware, or items outside of the United States – even to take them into International Waters without docking in another country. (The technology, data, or items are considered to be “controlled” if found on the Commerce Control List or the U.S. Munitions List). This includes the transfer of “controlled” technology, data, or items to foreign nationals within the U.S. or outside the U.S.

There are certain countries that are sometimes referred to as “Countries of Concern” due to their presence on one or more U.S. or international sanctions or embargo lists.

The U.S. Treasury’s Office of Foreign Asset Control (OFAC) enforces embargoes/sanctions against the countries below. Some of the sanctions are monetary in nature, and other sanctions may either prohibit shipping or require a license to ship. For example, the export of most items to Iran requires a license from OFAC. Please note: the item does not have to be military or sophisticated in nature to require a license.

The International Traffic in Arms Regulations (ITAR) also prohibits exports and sales of U.S. Munitions List items without a license to virtually every country (there are a few exceptions applicable to Canada). Under the ITAR, licenses will not be granted for exports, or providing “defense services” (i.e., any form of assistance) to a foreign person in the U.S. or elsewhere, to:

Except for a few limited circumstances and on a case-by-case basis, it is the policy of the United States to deny licenses, other approvals, exports and imports of defense articles and defense services destined for or originating in: