Are foreign nationals who are citizens of Cuba, Iran, Syria, North Korea, and Sudan subject to any special OFAC definitions concerning foreign nationality?

No. There is no special OFAC definition of foreign nationality; the EAR and ITAR definitions cited above apply (see question 11). However, the particular types of transactions and access for which these foreign nationals can be involved are, in some cases, specially determined by the EAR and ITAR regulations. For example, China, Cuba, Iran, Syria, North Korea, and Sudan are all 126.1 prohibited countries. Therefore, access to ITAR equipment or data here or abroad is prohibited and a license would not be granted.