Iran Sanctions and Travel
BEFORE YOU GO
If you are planning to travel to Iran or engage in a collaboration with an Iranian institution, please contact the Export Compliance Office (firstname.lastname@example.org, or 215-573-8817) before you:
- Travel to Iran to attend or participate in a conference or workshop
- Travel to Iran to engage in activities that are not listed under General License G (see below)
- Travel to Iran with anything other than personal belongings, equipment covered by an OFAC license, or equipment allowed under Iran General License D-1 (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
- Provide Iranian nationals that reside in Iran, or Iranian institutions, technical assistance or analysis
- Import from Iran or export to Iran
- Enter into any type of agreement with an Iranian institution
Depending on the activity, license applications for Iran can sometimes take several months to process, so please contact the Export Compliance Office well in advance of your expected travel dates.
General Authorizations Relevant to Penn-related Travel to Iran
The following information outlines certain activities and travel that do not require a specific license from OFAC:
General License G
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;
- 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, require a specific license from OFAC.
General License D-1
General License D-1 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, 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.)