A specific NRC license is required to export any NRC-controlled commodity to an embargoed destination (Cuba, Iran, Iraq, North Korea, Syria, and Sudan). The regulations authorizing general licenses in §§ 110.21 through 110.26 specifically exclude exports to embargoed destinations listed in §10 CFR 110.28. Shipments to a distributor or to a “middle man” in a non-embargoed destination do not relieve the exporter of the requirement to obtain a specific license for NRC-controlled commodities being exported to end users in embargoed destinations. Exporters must determine who the consignee or end user is for exports of any NRC-controlled commodities. If the consignee or end user is in an embargoed destination, then the NRC regulations require the exporter to apply for and obtain a specific NRC license authorizing the export of a specific commodity to a named ultimate consignee for a particular end use in the embargoed destination.
Additional information can be found in NRC Information Notice 2011-07: Specific License Required When Exporting to Embargoed Destinations Listed in 10 CFR 110.28, dated April 14, 2011.