Iran Sanctions

If you are planning to engage in any of the following activities, please contact the Export Compliance Office (expctrl@lists.upenn.edu, or 215-573-8817):

• Attend or participate in a conference or workshop organized in Iran
• Provide Iranian nationals that reside in Iran, or Iranian institutions, with:
  • technical assistance
  • data analysis
  • mentoring/advising services
• Travel to Iran to engage in activities that are not listed under General License G (see below)
• Work remotely on Penn-related projects while in Iran
• Travel to Iran with anything other than personal belongings, equipment covered by an OFAC license, or equipment allowed under Iran General License D-2 (see below)
  • Note that if personal belongings include any controlled item, a license will still be necessary
  • Penn-owned equipment and material may require a specific license
• Import from Iran or export to Iran
• Enter into any type of agreement with an Iranian institution
• Engage in research collaborations with Iranian nationals located in Iran or with Iranian institutions

If you are contemplating any of these activities, a license may be required. Depending on the activity, license applications for Iran can sometimes take several months or more to process, so please contact the Export Compliance Office well in advance of the contemplated activity.

The following information outlines certain activities and travel that do not require a specific license from OFAC:

Iran General License G authorizes accredited U.S. academic institutions (such as Penn) to establish and operate undergraduate and graduate academic exchange agreements with Iranian universities, including providing scholarships to participating Iranian students.

Educational activities that fall under General License G:

• Student participation in educational courses or noncommercial academic research at Iranian universities at the undergraduate level;
• Student participation in educational courses at the graduate level or noncommercial academic research at Iranian universities in the humanities, social sciences, law, or business at levels above the undergraduate level;
  • Note that this does not apply to online graduate-level courses or remote work–the activities must take place at a university in Iran;
• Participation by individuals in Iran or ordinarily resident in Iran in online undergraduate courses (including MOOCs) in the humanities, social sciences, law, or business, or introductory level science and engineering courses ordinarily required for the completion of undergraduate degree programs;
• Providing services to Iran in support of combating illiteracy, increasing access to education, and assisting in educational reform projects;
• Administering professional certificate examinations and university entrance exams and providing services necessary or required for admission to U.S. academic institutions to individuals in Iran or residents of Iran;
• Certain publishing-related activities
  • Note that this does not include research activities leading up to a publication

All other academic exchanges in Iran, including attending or presenting at academic conferences and workshops or providing mentoring/advising services to Iranian graduate students, postdocs, or faculty located in Iran, require a specific license from OFAC.

General License D-2 generally authorizes the export to Iran, and re-importation into the U.S., of certain hardware incident to personal communications including laptop computers and peripherals for such devices (including but not limited to consumer disk drives and other data storage devices) designated as EAR99 or classified on the Commerce Control List under Export Control Classification Numbers (ECCNs) 5A992.c (includes most smartphones and tablets), 5A991.b.2, 5A991.b.4, or 4A994.b. (Special rules may apply if you have certain encryption technologies installed on your device.) Please contact the Export Compliance Office if you are unsure whether your devices meet these criteria. (As a reminder, when you travel to Iran with a tangible item, you are “exporting” the item to Iran, even if you intend to bring it back with you to the U.S.)