Iran has been subject to numerous U.S. sanctions for decades. The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) administers and enforces most of these sanctions. OFAC maintains a resource center that presents the complicated and numerous Iran sanctions. One part of the Iran sanctions program involves the Iranian Transactions and Sanctions Regulations (ITR), codified at 31 CFR Part 560.

Schools must evaluate transactions with the government of Iran and with Iranian entities and citizens, to ensure that the transaction is permitted under the Iran sanctions laws. One transaction relates to the provision of online courses to individuals located in Iran. This activity is even more important today, given the increased use of online modalities in response to COVID-19.

The main questions are whether an Iranian student may take online coursework under the following separate conditions:

While present in the United States:

  • in F-1 status, having having entered on an F-1 visa
  • in F-1 status, having been approved for a change of nonimmigrant status after having entered on a nonimmigrant visa other than F-1
  • in a nonimmigrant status other than F-1
  • while in violation of nonimmigrant status

While outside the United States:

  • while physically present in Iran
  • while physically present in a country other than Iran or the United States

Delivery of some online educational services for students outside the United States is authorized by general licenses, which allow the activity specified in the general license without needing to apply for a specific license.

  • See General Licenses G and M, referenced in the Treasury Department's FAQ 853 on Iran Sanctions and transcribed below. General License G does not have a specific end date. On August 24, 2021, the Treasury Department extended General License M-1 until 12:01 a.m. eastern daylight time September 1, 2022.

These general licenses distinguish between undergraduate and graduate studies, field of study, and location of study. Online educational services not covered by a general licenses or otherwise exempt from the transactions and sanctions regulations must be authorized by a specific license granted prior to the provision of those services.

Schools must also determine if delivery of online educational services to Iranian students inside the United States is permissible, under 31 CFR 560.505.

Ensuring institutional compliance with export control laws is generally beyond an international services office's scope of authority and expertise, so these questions should be analyzed and determined by a school's export control office and office of general counsel. The international services office can assist the export control function at their institutions by:

  • Bringing the basic issue to the attention of the export control or general counsel office
  • Providing background information on important concepts like the difference between SEVIS status, nonimmigrant status, and nonimmigrant visas
  • Providing information on numbers of students and possible scenarios
  • Communicating to affected students once the export control function has properly analyzed issues and made determinations for the institution
Transcription of General License G
Transcription of General License M-1