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, including remote participation.
• Teach academic courses, or address students in classes at Iranian Universities, either in person or remotely.
• Provide Iranian nationals that reside in Iran, or Iranian institutions, with:
  • technical assistance
  • data analysis
  • mentoring/advising services
• Travel to Iran to engage in teaching or research activities.
• Work remotely on Penn-related projects while in Iran.
• Provide mentoring/advising services to graduate students, postdocs, or faculty located in Iran.
• Serving on a dissertation committee for students located 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/export material or data to/from Iran.
• Enter into any type of agreement with an Iranian institution or business
• 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:

This general license authorizes transactions necessary and ordinarily incident to the publishing and marketing of manuscripts, books, journals, and newspapers in paper or electronic format. Provided that the parties involved do NOT include the Government of Iran or anyone acting on behalf of the Government of Iran, the following transactions are authorized:

• Commissioning and paying for publications not yet created, consistent with industry norms.
• Co-creating or enhancing written works.
• Augmenting written publications (e.g., adding photos, artwork, translations, explanatory text).
• Substantive editing of written publications.
• Payment of royalties for written publications.
• Creating or undertaking a marketing campaign to promote a written publication.

Note that activities leading up to the creation of a manuscript (e.g., active research) does not fall under this general license. Research activities likely require a specific license and should be reviewed for sanctions concerns.

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.)