Foreign Universities Sanctioned by the Commerce Department

The following degree granting institutions appear on the Department of Commerce Entity List (as of December 2017). There are a number of other “research institutes” that are also sanctioned by the Commerce Department, not listed below

The Department of Commerce Entity List contains foreign persons including businesses, research institutions, government and private organizations, and individuals and other types of legal persons that are subject to export and transfer restrictions.

Research collaborations and the exchange of items or information with any Entity Listed institution, as well as visitors to Brown who are employed by, representatives of, or affiliated with any Entity Listed institution, must be vetted by the Export Control Officer.

country entity license requirement
China Sichuan University For all items subject to the EAR
China University of Electronic Science and Technology of China For all items subject to the EAR
Israel Ben Gurion University For computers above the Tier 3 level described in Section 740.7(d)
China 54th Research Institute of China, a.k.a.:
—China Electronics Technology Group Corp. (CETC) 54th Research Institute;
—Communication, Telemetry and Telecontrol Research Institute (CTI); and
—Shijiazhuang Communication Observation and Control Technology Institute.
For all items subject to the EAR

Beijing University of Aeronautics and Astronautics (BUAA), a.k.a.:
—Beihang University.

For all items subject to the EAR
China Chinese Academy of Engineering Physics, a.k.a.:
—Ninth Academy;
—Southwest Computing Center;
—Southwest Institute of Applied Electronics;
—Southwest Institute of Chemical Materials;
—Southwest Institute of Electronic Engineering;
—Southwest Institute of Environmental Testing;
—Southwest Institute of Explosives and Chemical Engineering;
—Southwest Institute of Fluid Physics;
—Southwest Institute of General Designing and Assembly;
—Southwest Institute of Machining Technology;
—Southwest Institute of Materials;
—Southwest Institute of Nuclear Physics and Chemistry (a.k.a., China Academy of Engineering Physics (CAEP)'s 902 Institute);
—Southwest Institute of Research and Applications of Special Materials Factory;
—Southwest Institute of Structural Mechanics;
(all of preceding located in or near Mianyang, Sichuan Province)
—The High Power Laser Laboratory, Shanghai;
—The Institute of Applied Physics and Computational Mathematics, Beijing; and
—901 Institute.
For all items subject to the EAR

Northwestern Polytechnical University, a.k.a.:
—Northwestern Polytechnic University;
—Northwest Polytechnic University; and
—Northwest Polytechnical University.

For all items subject to the EAR
China National Supercomputing Center Guangzhou (NSCC-GZ), Sun Yat-Sen University For all items subject to the EAR
China National University of Defense Technology (NUDT) For all items subject to the EAR

Higher Institute of Applied Science and Technology (HIAST), a.k.a.:
—Institut Superieur des Sciences Appliquées et de Technologie (ISSAT); and
—Institut des Sciences Appliquées et de Technologie (ISAT).

For all items subject to the EAR

Unverified List

The Unverified List (UVL) is a precursor to the Department of Commerce Entity List.  Parties are added to the UVL when there may not be sufficient information to add the foreign person/entity at issue to the Entity List.  Parties listed on the UVL are ineligible to receive items subject to the Export Administration Regulations (EAR) by means of a license exception and there are additional filing and documentation requirements if items are transferred to a party on the UVL.  The full list can be found in Supplement No. 6 to 15 CFR § 744.  However, there are several universities and research institutes on the UVL.  For example:

country University/Institute
China Anhui Institute of Metrology
China Shanghai Institute of Applied Physics
China Guangdong University of Technology
China Nanchang University


Sun Yat-Sen University

Hefei Institutes of Physical Science

China Southern University of Science and Technology, Department of Mechanical and Energy Engineering
China Hunan University, State Key Lab of Chemo/Biosensing and Chemometrics

*The above list is not exhaustive.

Foreign Universities Sanctioned by the Treasury Department 

The following universities appear on Office of Foreign Assets Control's (OFAC) Specially Designated Nationals list. As part of its enforcement efforts, OFAC publishes a list of individuals and companies owned or controlled by, or acting for or on behalf of, targeted countries. It also lists individuals, groups, and entities, such as terrorists and narcotics traffickers designated under programs that are not country-specific. Collectively, such individuals and entities are called “Specially Designated Nationals” or “SDNs.” Their assets are blocked and U.S. persons are generally prohibited from dealing with them.

Country University