Licence to Learn: OFAC issues GL for online Iranian students
The US Treasury Department’s Office of Foreign Assets Control (‘OFAC’) has issued a general licence, GLM-2, under ‘which accredited graduate and undergraduate degree-granting academic institutions located in the United States (collectively, “U.S. academic institutions”), including their contractors’ are authorized to engage with Iranian students in the following activities:
‘(1) Online Educational Services. The provision of online educational services related to graduate educational courses, provided that the courses are the equivalent of courses ordinarily required for the completion of graduate degree programs in the humanities, social sciences, law, or business, or are introductory science, technology, engineering, or mathematics courses ordinarily required for the completion of graduate degree programs in the humanities, social sciences, law, or business, and participation in all activities related to the provision of such online educational services to Iranian students described in paragraph (b).
‘(2) Exportation of Software. The exportation of software to Iranian students described in paragraph (b) in order to facilitate participation in the activities authorized in (i) paragraph (a) of this general license or (ii) paragraph (b)(1)(iii) of Iran General License G, provided such software is designated as EAR99 under the Export Administration Regulations, 15 CFR parts 730 through 774 (EAR), or constitutes information or software not subject to the EAR pursuant to 15 CFR § 734.3(b)(3).
Paragraph (b) explains that ‘Iranian students referred to in paragraph (a) are individuals located in Iran, or located outside Iran but who are ordinarily resident in Iran, who are eligible for non-immigrant classification under categories F (students) or M (non-academic students), and have been granted a non-immigrant visa by the U.S. State Department, but are not physically present in the United States due to the COVID-19 pandemic.’
