On Thursday, OFAC issued a new General License for the Iran sanctions program. General License G permits various educational transactions that were previously prohibited:
Academic Exchanges…accredited graduate and undergraduate degree-granting academic institutions located in the
United States … are
authorized to enter into student academic exchange agreements with universities located in Iran … related to undergraduate or graduate educational courses,
and to engage in all activities related to such agreements, including, but not limited to, the
provision of scholarships to students enrolled in Iranian universities to allow such students to
attend U.S. academic institutions.Educational Services…
(1) U.S. academic institutions … are authorized to export
services:
(i) in connection with the filing and processing of applications and the
acceptance of payments for submitted applications and tuition from or on behalf
of individuals who are located in Iran, or located outside Iran but who are
ordinarily resident in Iran;
(ii) related to the recruitment, hiring, or employment in a teaching capacity of
individuals who are located in Iran, or located outside Iran but who are ordinarily
resident in Iran, and regularly employed in a teaching capacity at an Iranian
university, provided that no such individuals are employed in a teaching capacity
within the United States without being granted appropriate visas by the U.S.
Department of State or authorization from the U.S. Department of Homeland
Security; and
(iii) to individuals located in Iran, or located outside Iran but who are
ordinarily resident in Iran, to sign up for and to participate in undergraduate level
online courses (including Massive Open Online Courses, coursework not part of a
degree seeking program, and fee-based courses) provided by U.S. academic
institutions in the humanities, social sciences, law, or business provided that the
courses are the equivalent of courses ordinarily required for the completion of
undergraduate degree programs in the humanities, social sciences, law, or
business, or are introductory undergraduate level science, technology,
engineering, or math courses ordinarily required for the completion of undergraduate degree programs in the humanities, social sciences, law, or
business.(2) U.S. persons who are actively enrolled in U.S. academic institutions are authorized to
(i) participate in educational courses or engage in noncommercial academic research
at Iranian universities at the undergraduate level, or (ii) participate in educational
courses at the graduate level or engage in noncommercial academic research at
Iranian universities in the humanities, social sciences, law, or business at levels above
the undergraduate level.
(3) U.S. persons are authorized to export services to Iran in support of the following not-
for-profit educational activities in Iran: combating illiteracy, increasing access to
education, and assisting in educational reform projects.
(4) U.S. persons, wherever located, are authorized to administer professional certificate
examinations and university entrance examinations, including, but not limited to,
multiple choice standardized tests, and to provide those services that are necessary or
required for admission to U.S. academic institutions, to individuals who are located in
Iran or located outside Iran but who are ordinarily resident in Iran.
There are the usual exceptions, of course (e.g. no SDNs)
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Filed under: Iranian Sanctions, Licenses, OFAC Updates