On March 19, the Office of Foreign Assets Control ("OFAC") issued a general license under the Iranian Transactions and Sanctions Regulations that authorizes several specific forms of academic exchanges with Iran.
The newly issued general license – General License G (the "License") – authorizes qualifying U.S. colleges and universities to engage in certain transactions related to Iranian students and educators. Additionally, the License makes provisions for U.S. persons to participate in certain educational activities in Iran. Finally, the License permits U.S. financial institutions to process funds transfers in furtherance of the licensed activities, so long as such transfers do not involve debiting or crediting an Iranian account, and to collect, accept, and process student loan payments from Iranian persons.
Accredited Colleges and Universities
Specifically, the License provides that accredited colleges and universities in the United States may enter into student exchange agreements with universities located in Iran and may engage in all activities related to such agreements, including the provision of scholarships to Iranian students to facilitate their attendance at a school in the United States. Qualifying academic institutions may also export services related to their application processes and tuition fees, as well as services related to signing up for and participating in undergraduate-level online courses offering specified courses of study. Under the License, qualifying academic institutions may additionally export services related to the recruitment, hiring, or employment of Iranian persons who are regularly employed as teachers at an Iranian university.
U.S. Persons
Furthermore, the License authorizes U.S. persons to engage in certain educational activities in Iran. U.S. persons actively enrolled in accredited U.S. colleges and universities may participate in educational courses and noncommercial academic research in specified areas of study at Iranian universities. U.S. persons may export services in support of specified not-for-profit educational activities in Iran, including combating illiteracy, increasing access to education, and assisting in educational reform projects. Additionally, under the License, U.S. persons may administer professional certificate examinations and university entrance examinations to Iranian persons.
U.S. Financial Institutions
The License qualifies the colleges, universities, and persons that may participate in the exchanges and limits eligible degree programs and areas of study. Additionally, the License specifically does not authorize the exportation or reexportation of any goods or technology to Iran or the Government of Iran, with the exception of technology or software released under the License that is designated as EAR99 under the Export Administration Regulations ("EAR") or constitutes Educational Information not subject to the EAR, if the release does not otherwise require a license from the Department of Commerce. Entities utilizing the License should review OFAC General License D-1, which authorizes certain exports to Iran of equipment incident to personal communication. See our previous guidance on the use of General License D-1. See our previous guidance on the use of General License D-1.
This article is presented for informational purposes only and is not intended to constitute legal advice.
