Overview
Due to Iran’s status as a comprehensively-sanctioned country, most transactions and dealings with Iranian individuals, businesses, and government entities are prohibited.
Certain exceptions may exist for humanitarian purposes, but these are often narrow and require specific licensing. Additionally, UCSF must take special compliance measures for students, visiting scholars, and other collaborators from Iran. Many activities involving Iran will require an Export Control license, in which case [email protected] should be contacted as early as possible before agreeing to engage in any activity.
General Licenses for International Students and Visiting Scholars at UCSF
Authorization for Iranian Nationals to Learn and Work at UCSF
OFAC General License G (31 CFR Part 560) authorizes Iranian nationals who are otherwise eligible for F-1 Student, J-1 Student and Scholar, and H-1B Specialty Occupation visas to carry out those activities at UCSF for which the U.S. Department of Homeland Security has granted them such non-immigrant visas.
OFAC General License G does NOT authorize the exportation of any UCSF commodity, software, or technology to Iran.
OFAC General License G DOES authorize the “release” or “deemed export” of technology or software to Iranian students at the UCSF if all the following conditions are met:
- Such release is ordinarily incident and necessary to the educational program in which the student is enrolled.
- The technology or software being released is designated as EAR99 under the EAR or constitutes “educational information.”
- The release does not otherwise require a license from the U.S. Department of Commerce.
- The student to whom the release is made is not enrolled in school or participating in the educational program as an agent, employee, or contractor of the Government of Iran or a business entity or other organization in Iran.
Online Learning Considerations: It is important to note that, even if a student from Iran obtains a valid visa to participate in an educational activity at UCSF, any online participation (if they are located in Iran) may be significantly hindered by technical and compliance barriers. Due to OFAC-related restrictions, Iranian users typically cannot access key UCSF systems and services, including (but not limited to) Duo (two-factor authentication), Zoom (video conferencing), and Microsoft Office 365 (email and productivity tools). Furthermore, UCSF’s network blocks all internet traffic to and from Iran, meaning the student would not be able to connect to campus systems from within Iran.
Collaborating with Iranian Scholars
In most cases, university researchers will require a specific license from OFAC to conduct research-related activities in Iran and to engage in research-related activities with scholars located in Iran. The licensing process can be time-consuming and requires detailed information about the proposed research.
A "Publishing Exemption" exists and authorizes US Persons to engage in any transactions “necessary and ordinarily incident to the publishing and marketing of manuscripts, books, journals, and newspapers in paper or electronic form.” (31 CFR 560.538). This exemption permits collaboration on the creation or “enhancement” of written publications, including translating, substantive editing, co-authoring or reviewing of materials, and does not include sharing or importing of data or samples used in the publication, the provision of goods or services not necessary and ordinarily incident to publishing and marketing of publications, such as legal, accounting, design, or consulting services. However, it does not apply if the Iranian parties represent the Government of Iran or are included in any denied parties lists and does not include research activities leading up to a publication.
Shipping Items to Iran
UCSF and its employees are prohibited from physically shipping anything to Iran. The Export Control Officer may, in very certain circumstances, apply for an export license for a physical shipment. Please contact [email protected] to discuss.
Travelling to Iran
Business travel to - including attending a conference in or performing research in - Iran is not openly permitted.
Payments to Iran
No payments may be processed to or from Iranian financial institutions or other prohibited sources.
Additional Examples of When a Specific License May be Required
1. A U.S. person attending any conference in Iran.
2. Provisioning or providing services including dissertation or thesis advising to a person/entity who is in Iran.
3. Substantive enhancement of any information that are not fully created and in existence in the public domain.
4. Teaching services, including online programs, to people located in Iran, including, but not limited to, instruction, reviewing any work, and grading the work.
5. Providing mentoring/advising services to Iranian graduate students, postdocs, or faculty located in Iran.
6. A license may be required if collaboration requires importing data/materials for analysis in the U.S., even if fundamental research and published, when the results will be provided to someone in sanctioned countries (e.g. characterization of material and providing the results to a researcher in Iran).