Suspension of Iran-Related General Authorizations
Overview
On August 24th, the Department of Treasury, Office of Foreign Assets Control (OFAC) issued a notice that “indefinitely” suspended General License G (GL G). This action closed a limited exception to the comprehensive sanctions against Iran which allowed US institutions to accept applications from or enroll students who are ordinarily resident in Iran. Also closed was a limited exception that allowed recruitment, hiring or employment of an individual who is ordinarily resident in Iran and teaching at an Iranian university.
How is "Ordinarily Resident in Iran" Defined?
OFAC does not provide a definition of this term; however, the definition is presumed to include (but may not be limited to):
- Someone whose usual or customary place of residence is Iran (regardless of nationality), even when temporarily outside the country
- Any individual residing in Iran
- Iranian national who is on a visa to a third country which, if revoked, would require the individual to return to Iran
Who Does This Impact?
Prospective students located in Iran or "ordinarily resident" there
- While GL G is suspended, universities are no longer authorized to process applications or accept application fees and tuition from—or on behalf of—these individuals.
- Authorizations for university entrance and professional certification examinations are also suspended.
- UMD is no longer permitted to process applications, accept tuition payments, or issue scholarships for individuals in Iran without a specific license.
- UMD does not interpret this suspension to apply to actively enrolled students presently in the US under a valid visa
Students receiving remote instruction in Iran
- With GL G suspended, universities are no longer authorized to provide remote instruction to or grant access to online courses to individuals located in Iran.
- This prohibition includes Massive Open Online Courses (MOOCs), certificate granting programs, or other educational services such as lectures, seminars, etc.
- UMD is no longer permitted to offer online courses to individuals located in Iran.
Faculty candidates located in Iran or ordinarily resident there
- GL G’s authorization for certain recruitment, hiring, and teaching employment involving individuals regularly employed as teachers at Iranian universities is suspended.
- UMD is not permitted to recruit, hire, or employ in a teaching capacity individuals currently teaching at Iranian universities.
Iranian students and employees in the United States
- Qualifying study and employment activities generally may continue for those individuals already in the United States with a valid visa or under separate authorization, subject to applicable immigration, sanctions, and export-control conditions.
Exchange participants and U.S. students studying in Iran
- Universities can no longer rely on GL G for student exchange agreements with Iranian universities or associated scholarships and activities.
- Previously covered study and noncommercial research by U.S. students at Iranian universities require separate authorization.
Overseas campuses, conference participants, and individuals transferring funds
- Related suspensions affect certain educational activities in third countries (§ 560.544), conference services in the United States or third countries (§ 560.554), and personal remittances (§ 560.550).
- UMD cannot facilitate, sponsor, or support the participation of Iranian residents in conferences or similar events in the United States or other countries, nor can UMD personnel attend conferences in Iran (including remote participation).