This page was last updated in July 2022. The U.S. government has since expanded the list of sanctioned entities significantly. For updated guidance on working with Russian institutions, contact exportcontrolhelp@mit.edu.
In response to the Russian government’s invasion of Ukraine, the United States government has announced sanctions on a number of Russian individuals and entities. This page is intended to help MIT’s principal investigators understand the restrictions on collaborations with peers at sanctioned institutions, as well as the potential risks involved in starting or continuing informal collaborations with peers at Russian institutions that have not been sanctioned.
Please be sure to read this August 5 message from Vice President for Research Maria Zuber regarding new sanctions that prohibit collaborations with peers at certain Russian high-technology entities, as well as this May 18 message from Zuber regarding informal collaborations more broadly.
Q: Is MIT prohibiting informal collaborations with peers at Russian institutions?
A: No, MIT is not prohibiting such collaborations, nor is it making any change to Institute policies. However, under new sanctions announced by the U.S. government on August 2, collaborations with peers at some Russian high-technology entities are prohibited by law. Please review the list of sanctioned entities, as well as Vice President Maria Zuber’s message about these sanctions.
For Russian institutions that are not sanctioned, there remains the risk that new rounds of sanctions could place informal collaborations in violation of U.S. law without advance notice, causing collaborators to stop work immediately. This is a serious matter, and it is important that PIs have the information they need to safeguard their work.
Q: Do sanctions apply to any informal collaboration with peers at Russian institutions?
A: The sanctions announced in August prohibit all collaborations or other academic or publication-related activities with peers at a listed entity. We cannot say if future sanctions, affecting other entities, would apply in the same way. Informal collaborations that are acceptable under current law, including but not limited to those involving technology research, could be prohibited under new sanctions. Because the Institute does not track informal collaborations, we have no way of alerting individual PIs to changes in U.S. policy that would affect an ongoing or proposed collaboration. For this reason, our general advice is to discontinue ongoing collaborations and to avoid starting new ones. Ultimately, however, this is a decision that each PI must make individually.
Q: Do these sanctions mean that I cannot engage in communications of personal nature with friends at sanctioned entities?
A: Even as we condemn the Russian government’s action in the strongest terms, we affirm our belief in the many individual Russian scholars who have made important contributions to knowledge and learning. In this difficult time, we recognize that some MIT researchers may wish to communicate with Russian peers on personal terms. Email and telephone communications with individuals at an organization on the list of sanctioned entities generally are permissible if they are of a purely personal nature. We advise using personal email addresses or telephone numbers for such communications.
Q: Who can I reach out to if I have questions about a specific collaboration?
Greg Moffatt, MIT’s Chief Research Compliance Officer, is available to help PIs assess specific cases. He can be reached at gtm@mit.edu.
*Informal collaborations may include, but are not limited to, activities such as conversations, sharing of ideas and sharing of data with researchers from other institutions where there is no written agreement, no required deliverables, and no funds exchanged between the participants to pay costs of the collaboration, or for any other purpose. Such informal collaborations may result in joint publications between MIT researchers and those of other institutions.