Iran Sanctions

The diplomatic relationship between the U.S. and Iran is affected by numerous geopolitical factors and is subject to change on short notice. In May 2018, the U.S. withdrew from the Joint Comprehensive Plan of Action (JCPOA), the agreement under which the U.S. had relaxed its sanctions program. While limited commercial activity is permitted with Iran, the majority of the U.S. Office of Foreign Assets Control's (OFAC) sanction program remains in effect for Iran. If your research involves collaboration with, or travel or shipping to, an Iranian entity or individual(s), contact export_controls@ncsu.edu for consultation.

Education Services

Under General License G issued by OFAC, U.S. academic institutions are permitted to provide certain educational services and academic exchanges with Iranian universities and students. Iranian students may apply for non-immigrant visas to attend academic institutions in the U.S. Iranian students may also participate in undergraduate-level online courses provided by U.S. academic institutions in the humanities, social sciences, law or business that are the equivalent to courses ordinarily required for the completion of undergraduate degree programs in the humanities, social sciences, law or business — or in introductory-level science, technology, engineering, or math courses that are ordinarily required for the completion of undergraduate degree programs in the humanities, social sciences, law or business.

U.S. persons who are actively enrolled in a U.S. academic institution are authorized to participate in educational courses and engage in noncommercial academic research at Iranian universities at the undergraduate level. Participation in graduate-level courses and noncommercial academic research in the humanities, social sciences, law or business is also permitted.

This authorization for education services is nuanced with stipulations that are too numerous to list here. If you’re interested in providing or obtaining educational services to or from Iran, contact export_controls@ncsu.edu for consultation.

Research Activities

Outside of the undergraduate and limited graduate-level research explained above, research collaborations between NC State and Iranian entities remain restricted under OFAC’s sanctions program. While certain research results may be exempt from export controls under the Fundamental Research exclusion, most of the mechanisms and activities involved in sharing this information and collaboration between a U.S.-based entity and an Iranian entity to conduct research are prohibited.  The foundation for this prohibition is that, except for the education services explained above, a U.S. entity — including individuals operating under U.S. jurisdiction — is prohibited from providing services to Iranian entities — including individuals operating under Iranian authority. The nuances of these prohibitions are too many to list here, so if you are seriously considering a research endeavor involving an Iranian entity in any way, contact export_controls@ncsu.edu for a consultation.

OFAC has a licensing process whereby specific authorizations for a proposed research effort may be requested. This process is lengthy, in some cases taking more than a year, and there is a general policy of denial for these requests. Contact export_controls@ncsu.edu for more information.

Shipping

Physical shipments of goods from the U.S. to Iran are prohibited by both OFAC and Bureau of Industry and Security (BIS). Both agencies have mechanisms to apply for licenses to allow the export of items to Iran; however, each agency has a policy of denial for most cases. If a proposed export is in support of an approved activity in Iran (i.e., educational exchange), there is a better chance of obtaining approval.

Information and informational materials are generally permitted for shipment between the U.S. and Iran, provided that these materials do not contain information that is controlled for export under the Export Administration Regulations (EAR) and they are not altered or enhanced after shipment. Examples of informational materials include publications, films, posters, phonograph records, photographs, microfilms, microfiche, tapes, compact disks, CD ROMs, artworks and newswire feeds.

Contact export_controls@ncsu.edu for instruction on any potential shipments destined to Iran.

Travel

Travel to Iran to attend or present at an open conference will require a license from OFAC. Similarly, a presentation via webinar to a live audience that includes individuals inside Iran would also require a license from OFAC. These licenses generally take four to six months to process, but in some instances, they may take a year or more. If you are interested in conducting any of these activities, contact export_controls@ncsu.edu as early as possible for consultation and assistance.