Sanctioned Countries Data Standard

Intended Audience and Contact Information

Contact	Chief Data Officer, Office of the CIO
UDM Domain	Location
Intended Audience	Internal UBC

Purpose

This standard aims to impose a list of relevant countries from which UBC is prohibited from transacting certain business without prior specific government approval.

This standard list of countries is based on sanctions imposed by government of Canada and the United States of America. The prohibitions apply to all UBC applications transacting certain business with any persons, companies, higher education institutions, NGOs and / or government departments named in the relevant countries without obtaining the prior written permission of the Canadian government, in advance of transactions. Penalties include significant fines and prison sentence, both for individuals, UBC and the corresponding financial institutions.

Standard

Current sanctions imposed by UBC

The list of sanctioned countries adopted by UBC is governed by UBC Treasury. The sanctioned countries are compiled based on current sanctions list imposed by Canada and the US periodically. The list of relevant countries are:

Albania
Belarus
Bosnia and Herzegovina
Bulgaria
Burundi
Central African Republic (the)
Congo (the Democratic Republic of the)
Croatia
Cuba
Eritrea
Greece
Iran (Islamic Republic of)

Iraq
Korea (the Democratic People's Republic of)
Lebanon
Libya
Mali
Montenegro
Myanmar
Nicaragua
North Macedonia
Romania
Russian Federation (the)
Serbia

Slovenia
Somalia
South Sudan
Sudan (the)
Syrian Arab Republic (the)
Tunisia
Turkey
Ukraine
Venezuela (Bolivarian Republic of)
Yemen
Zimbabwe

Sanctioned Entities

As a member state of United Nation (UN), sanctions imposed by Canada are not limited to specific countries. Sanctioned geographic region, such as Balkans, may include several countries.

Type of sanctions

The nature of sanctions imposed by Canada under different laws and regulations are of the following types:

Arms and related materials embargo
Asset freeze
Export and import restrictions
Financial prohibitions
Technical assistance prohibitions

More details are available on the Government of Canada website:
https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/types.aspx?lang=eng

Current sanctions imposed by Canada

The list of sanctioned countries as published by the Government of Canada has been adopted as part of the relevant countries observed by UBC. The list of current sanctions imposed by Canada is available on the Government of Canada website:
https://www.international.gc.ca/world-monde/international_relations-relations_internationales/sanctions/current-actuelles.aspx?lang=eng

Current sanctions imposed by the US

The list of sanctioned countries as published by the Office of Foreign Assets Control (OFAC) of the US Department of Treasury has been adopted as part of the relevant countries observed by UBC. The list of current sanctions imposed by OFAC is available on the OFAC website:
(TBC) https://www.treasury.gov/resource-center/sanctions/SDN-List/Pages/Other-OFAC-Sanctions-Lists.aspx

Compliance

This standard about Sanctioned Countries must comply with every stage of the data lifecycle at UBC with the exception of any dispensations (see Dispensation section):

All applications are prohibited from transacting certain business without specific prior government approval according to current sanctions as outlined in this standard.
Enterprise Data Integration must adopt this standard.

Dispensation

No systems are exempt from this data standard. As existing systems change to adopt this standard, the Enterprise Data Governance team needs to be informed.

Appendices

Effective date
Standard owner	Chief Data Officer, Office of the CIO.
Author	Kimmis Chow, Enterprise Data Architect – Office of the CIO
Contributors	Otto Wong – UBC Treasury
Status	Final
Approved DGSC	Approved