Overview
Due to comprehensive U.S. sanctions applicable to Iran, most transactions, services, and other activities involving Iran, persons located in Iran, Iranian institutions, or the Government of Iran are prohibited unless exempt or specifically authorized by the U.S. Government.
All new or ongoing UCSF activities and services involving Iran, Iranian institutions, or persons located in Iran must be reviewed by Research Security and Export Control before proceeding. This includes research and academic collaborations, publication or co-authorship relationships, educational activities, conferences, payments or support, travel, shipments, and transfers of data, software, technology, equipment, biological materials, or other research resources.
Activities that were previously reviewed or approved by Export Control must be re-reviewed if they involve Iran, an Iranian institution, or a person located in Iran and may have relied on one of the OFAC general licenses suspended on August 24, 2026. Activities that remain authorized under a valid specific OFAC license or another applicable exemption or authorization may continue only if Research Security and Export Control confirms that the authorization remains valid and applicable. If a specific OFAC license is required, the activity must cease or remain paused until the license is obtained.
Contact [email protected] as early as possible and before beginning or making a commitment related to a new Iran-related activity, modifying a previously approved activity, or proceeding with an ongoing activity that may be affected by the August 24, 2026, suspension or for which you are uncertain whether prior approval remains valid.
Departments and program leaders should work with Research Security and Export Control to identify potentially affected ongoing activities involving Iran, Iranian institutions, or persons located in Iran.
Important OFAC Update
On August 24, 2026, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) indefinitely suspended several general licenses under the Iranian Transactions and Sanctions Regulations that previously authorized certain academic, educational, conference, and other activities involving Iran. OFAC suspended five general licenses, and activities relying on those suspended authorizations must cease effective September 8, 2026, unless they can be completed under General License BB or are otherwise authorized. The suspended authorizations include Iran General License G, certain educational activities under 31 C.F.R. § 560.544, and certain conference-related services under 31 C.F.R. § 560.554.
OFAC also issued General License BB, which provides a limited authorization through September 8, 2026, for certain transactions ordinarily incident and necessary to wind down activities that were previously authorized under the suspended general licenses.
Because the availability of these prior authorizations has changed, all new or ongoing UCSF activities and services involving Iran, an Iranian institution, or a person located in Iran must be reviewed by UCSF Research Security and Export Control before proceeding.
This includes, but is not limited to:
- Research and academic collaborations
- Funded or unfunded activities
- Teaching, mentoring, advising, or other educational services
- Conferences or academic exchanges
- Sharing data, software, technology, equipment, biological materials, or other research resources
- Payments, research support, reimbursements, or sponsored travel
- Shipping or receiving items or materials
- Publication or co-authorship relationships
Do not initiate a new activity, modify an existing activity, or continue an ongoing activity involving Iran, an Iranian institution, or a person located in Iran until Research Security and Export Control has determined whether the activity remains authorized. If a prior approval relied on, or may have relied on, one of the OFAC authorizations suspended on August 24, 2026, contact Export Control before proceeding. If a specific OFAC license is required, the activity may not proceed until the license has been issued.
OFAC specific license applications may take 3–12 months or longer for federal review, and approval is not guaranteed. Researchers and departments should therefore contact Export Control as early as possible when planning an activity that may require authorization.