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.