EXPORT CONTROL GUIDELINES

SatProf, as a U.S. company, and GVF and SatProf staff, as U.S. nationals, are required to comply with U.S. laws, including those relating to export controls, sanctions, and embargoes under the U.S. State Department’s Office of Foreign Asset Controls (OFAC). We require students and customer organizations to confirm that GVF or SatProf training resources or accounts ("GVF Training") is not assigned to students in any way that contravenes U.S. law. Following is a summary of those requirements.

A. GVF and SatProf may not provide online training services to any student who is:

  • Physically located in any of the below Restricted Countries* while they are using the GVF Training, including online courses,
  • Known to be ordinarily resident in any of the Restricted Countries, or
  • Can be expected to use the skills and knowledge acquired from GVF Training in a Restricted Country

unless the student is an employee or contractor of an Excepted Organization (defined below), and GVF Training is used by the student only for conduct of the Excepted Organization’s official business, as agreed and certified by that organization.

*The Restricted Countries include Cuba, Iran, North Korea, Syria, and the Crimea region claimed by Russia.

**The following are Excepted Organizations:

  • US government.
  • Bona fide United Nations agencies, programs and funds (except in Crimea).
  • Contractors to the UN, but only upon obtaining a copy of the contractor's contract with the UN Agency to confirm that the GVF Training is (a) within the scope of the contractor’s contract with the UN Agency, and (b) for the official business of the UN Agency.
  • For Cuba only: Any intergovernmental organization in which the US is a member for conduct of official business.
  • For Iran only: World Bank, the International Monetary Fund, the International Atomic Energy Agency, the International Labor Organization, or the World Health Organization.
  • OFAC-licensed Non-Governmental Organizations (NGOs), but only (a) upon obtaining a copy of the OFAC license and (b) when GVF Training is within the scope of the authority granted in that license.
  • Contractors to OFAC-licensed NGOs, but only (a) upon obtaining a copy of the NGO's OFAC license to confirm that GVF Training is within the scope of the authority granted in the NGO's license, and (b) upon obtaining a copy of the the contractor's contract with the NGO, to confirm that GVF Training is within the scope of the contractor’s contract with the NGO.

B. GVF and SatProf may not provide GVF Training to any student who appears on an OFAC Specially Designated Nationals (SDN) list, or who is an employee or contractor of an entity on the OFAC SDN list, or that is owned 50% or more by a person or entity on the SDN list.

C. GVF and SatProf reserve the right to withhold training to any student if GVF or SatProf determine that providing such training may be in conflict with any U.S. law.

D. Enrollment in certain training courses may require additional approval from other organizations, such as GVF’s training content partners, who may impose additional restrictions at their own discretion.


As part of the GVF/SatProf export control compliance review process, we request that you complete this form, sign, and return it with the requested attachments.

Q1. Will you assign any GVF Training to:

  1. Any student physically located in any of the following countries while using GVF Training (including online courses); or
  2. Any student who is known to be ordinarily resident in any of these countries; or
  3. Any student who can be expected to use the skills and knowledge acquired from GVF Training in these countries?
Cuba:
Iran:
N. Korea:
Syria:
The Crimea region claimed by Russia:

If you answered Never to all of the above, skip to Q12.

Q2. My organization is directly covered by General License(s) from the U.S. Office of Foreign Access Controls (OFAC) for the following countries:

Q3. My organization is has Special License(s) from the U.S. Office of Foreign Access Controls (OFAC) for the following countries:

If you answered None to Q2 and Q3, skip to Q6.

Q4. Is GVF Training within the scope of the authority granted in your organization’s General and/or Special OFAC license(s)?

Q5. Will the GVF Training be used by any students described by Q1 only for your organization's official business?

If you answered Yes to Q4 and Q5, please provide a copy of your OFAC license(s).

Q6. Is your organization a subcontractor to another contracting organization which holds an OFAC general or special license?

If no, skip to Q12.

Q7. What is the name of the contracting organization?

Q8. The contracting organization is directly covered by General License(s) from the U.S. Office of Foreign Access Controls (OFAC) for the following countries:

Q9. The contracting organization has Special License(s) from the U.S. Office of Foreign Access Controls (OFAC) for the following countries:

Q10. Is GVF Training within the scope of the authority granted by the contracting organization's General and/or Special OFAC licenses?

Q11. Will the GVF Training be used by any students described by Q1 only for the contracting organization's official business?

If you answered Yes to Q11, please provide a copy of your contract.

Q12. Will you assign any GVF Training to any student who appears on an OFAC Specially Designated Nationals (SDN) list, or who is an employee or contractor of an entity on the OFAC SDN list or that is owned 50% or more by a person or entity on the SDN list?


I certify that the above answers are correct.