Additional Info - Export Control

Sanctions: Iran

Academic Collaboration Activities

Guide to U.S. Iran Sanctions

The U.S. Department of Treasury, Office of Foreign Asset Controls (OFAC) administers U.S. sanctions against Iran and other countries. There are serious penalties for violations. The University has a strong commitment to its academic mission, which must be balanced with the obligation to comply with U.S. law. This guide outlines activities that can be lawfully conducted in the context of academic collaboration with citizens of Iran.

This guidance is intended to provide faculty with a framework for lawful and unlawful activities when a citizen of Iran (including dual citizens of Iran and another country) is in one of three travel categories, as follows:

  1. Iranian person is temporarily traveling outside the United States, but holds a valid U.S. visa with currently-valid authorization to enter the United States;
  2. Iranian person located in a country other than Iran, outside the United States, with no currently-valid authorization to enter the United States;
  3. Iranian person located in Iran either temporarily or indefinitely with or without a valid U.S. entry.

 

Activity Applicable Law
Always permitted: educational activities for students physically in the United States While a student is within the territory of the United States on a valid visa (including F and J visas) U.S. persons are authorized to take any actions necessary to give effect to the activity authorized by the visa. This authorization includes permission to provide teaching and academic advice, preparing, defending, or advising on a dissertation or academic thesis, research activities, and other educational services. This authorization also includes permission to conduct financial transactions necessary to give effect to the activity authorized by the visa.
Always permitted: activities related to publishing for all three travel categories

Even if an academic colleague who is an Iranian citizen is outside the United States, U.S. persons are authorized to engage in transactions necessary and ordinarily incident to the publishing and marketing of manuscripts, books, journals and newspapers. This includes permission to collaborate on the creation and enhancement of written publications, and substantive editing of written publications. This authorization includes permission to conduct such activities even when one party is physically located in Iran.

  • OFAC has indicated that it does not consider a dissertation or academic thesis to be a published work under this authorization. Therefore, this authorization does not apply to activities in connection with preparing, defending, or advising on a dissertation or academic thesis.
Always permitted: export and import of informational materials for all three travel categories

Even if the Iranian colleague is outside the United States, U.S. persons are generally authorized to exchange with such colleague any unaltered information and informational materials, whether commercial or otherwise, regardless of format or medium of transmission.

  • "Information and informational materials" includes publications, films, posters, phonograph records, photographs, microfilms, microfiche, tapes, compact disks, CD ROMs, artworks, and news wire feeds.
  • This authorization does not apply to materials not fully created and in existence at the date of the transaction.
  • This authorization also does not apply to the export of software or technology subject to export controls.
Always permitted: personal communications for all three categories Even if the Iranian colleague is outside the United States, U.S. persons are authorized to send and receive personal communications, so long as the communications do not involve the transfer of anything of value or the provision of a service.
Permitted in certain circumstances: financial transactions

U.S. persons are permitted to transfer funds to Iranian persons' bank accounts in the United States if the Iranian person is in the United States on a valid visa, or is outside the United States with a valid U.S. visa and a currently-valid U.S. entry authorization (travel category 1).

If an Iranian person is outside the United States in a third country (i.e., travel category 2) or in Iran (i.e., travel category 3) with no currently-valid authorization to enter the United States, then U.S. persons should suspend payments that would benefit the Iranian person until that person is authorized to return to the United States.

Permitted in certain circumstances: export of services to Iranian persons outside the United States

You may provide academic services such as teaching, advising, supervising research or providing distance education to an Iranian person who is traveling outside the United States and has a valid U.S. visa with a currently-valid authorization to enter the United States (travel category 1).

U.S. persons are generally prohibited from exporting services, directly or indirectly, from the United States or elsewhere, where the benefit of such services is received in Iran. Under this prohibition, you may not provide academic services such as teaching, advising, supervising research, or providing distance education where the benefit of those services is received directly or indirectly in Iran.

If the Iranian person is in a third country (i.e., travel category 2), the prohibition applies if the benefit of your services is received directly or indirectly in Iran. You should seek legal advice for these circumstances.

Prohibited: export of services U.S. persons are generally prohibited from exporting services, directly or indirectly, from the United States or elsewhere, to Iran. Under this prohibition, you may not provide academic services such as teaching, advising, supervising research or providing distance education to an Iranian person who is in Iran with no currently-valid authorization to enter the United States (travel category 3), unless that activity is a publishing activity, a transaction in information or informational materials, or is a purely personal communication, identified in green above.
Prohibited: transactions with SDNs The University must screen transactions for the involvement of Specially Designated Nationals (SDNs). OFAC's SDN List designates several individuals and entities from Iran. Those individuals and entities are subject to an asset freeze. In addition, several individuals and entities from Iran are subject to a travel ban pursuant to designation on the SDN List.
Export control prohibitions In addition to the comprehensive sanctions on Iran, the Departments of State and Commerce impose strict export control restrictions on Iran. When exporting information or commodities that may be controlled, the University should analyze whether such exports are exempt (for example, due to the fundamental research exemption) or whether authorization from the State Department or Commerce Department must be secured.