Sanctions

Sanctions are penalties applied by a country or institution against other countries, organizations, or individuals to enforce international norms and laws. Your research activities may be subject to export, import, and technical assistance prohibitions, as well as limitations, outright bans, or freezing of financial transactions. Learn more about relevant sanctions below and how they may apply to your research.

Government of Canada Sanctions Legislation

The Government of Canada uses sanctions as a foreign policy tool "for maintaining and restoring international peace and security, combatting corruption, and promoting respect for norms and values, including human rights." These sanctions place restrictions on the permissible activities between Canadians, residents of Canada, and foreign states, individuals and/or entities, in order to enforce international law and incite policy change. .

There are potential implications for university activities and research collaborations involving individuals and entities that are sanctioned. These may include prohibitions on the university to transfer funds (e.g. a research stipend) and to provide technical assistance to any sanctioned person or entity. Canadian regulations include mechanisms for the Minister of Foreign Affairs to issue permits or certificates to authorize specified activities or transactions that are otherwise prohibited, including providing humanitarian aid.

Assessing Sanctions Implications

When collaborating with individuals or other entities (e.g. universities, research institutions or companies) in sanctioned countries, students, staff, and faculty should take the appropriate measures to ensure they remain compliant with the current Canadian sanctions. Similar to the re-export of export-controlled goods from another country, special care and consideration must also be paid to the transfer of foreign goods and/or funds to countries, groups, or individuals covered by another country’s sanction list. We strongly advise caution when considering the transfer of research materials or funds to another country when they originate from the United States in particular (e.g., the National Institutes of Health). 

For example, if the Government of Canada sanctions The Moscow State University Quantum Technology Centre and those sanctions include an arms embargo, asset freeze, export/import restrictions, financial prohibitions, and/or technical assistance prohibition, a UBC researcher is prohibited from entering into agreement where products, technology, intellectual property or funding are transferred to that entity as they are subject to Canadian laws and regulations.  

Questions to Consider for International Collaborations

When planning activities with potential sanctions implications, consider:

  1. Could the partner you are dealing with be working on behalf of a designated person or entity, such as the organization of conference or speaking engagement? 
  2. Does the activity involve or benefit any sanctioned individuals or entities? 
  3. If you are inviting a visiting student or scholar Canada, are they from a sanctioned entity, and will they continue to collaborate with individuals at that sanctioned entity during their visit?
  4. If you are travelling to a sanctioned country to provide a talk, will it include technical advice or discussion of unpublished research? 
  5. If you are making or receiving a payment to or from a person or entity (either directly or indirectly), or through a bank, are they located in a sanctioned country? 

If you answered yes or unsure to any of the above questions, please consult with the Office of the University Counsel for additional guidance.


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