Working with students, or others, from Iran poses extra issues because of Iran’s status as an embargoed country. This guidance is intended to address common questions about working with students or others of Iranian citizenship. Because of the complexities, we encourage you to contact Linda Morris, the Export Controls Administrator, if you have any questions.
Are there restrictions on Iranians studying in the US?
Like all international students, Iranian students must receive a visa in order to study at CU. Currently, students planning to study for a career in the energy sector, nuclear science, nuclear energy, aerospace engineering, or a related field are likely to be denied visas by the Department of State.
If a student from Iran receives a student visa, he or she generally may enroll in any courses offered by CU. In some very limited cases, foreign students may be restricted from certain activities or sections of a course that would expose the students to technology or technical data that are restricted by US export control laws.
Iranian students may also be prohibited from working on some research projects that involve export-controlled technology or technical data. Generally this would occur only if the research was not intended to be published in the public domain, or if it involved access to equipment or software that is export-controlled. Contact Linda Morris in the Export Control Office whenever international students are involved in research to be certain that a license is not required.
International students should not share information related to export-controlled research projects to any non-US parties, nor should they ship or travel with any export-controlled items or software.
Can I work with former students or others who are living in Iran?
If the research involves export-controlled technologies, there are significant limitations on working with Iranian collaborators and licenses are difficult to obtain. Check with the Export Control Office before even having preliminary discussions.
If the collaboration does not involve export- controlled technologies on the Department of Commerce Commodity Control List or the Department of State US Munitions List, there still may be restrictions imposed by the Department of Treasury’s Office of Foreign Asset Control (OFAC). OFAC enforces the Iranian Transactions and Sanctions Regulations (ITSR; 31 CFR 560), which broadly (and strictly) prohibit the importation or exportation of ANY goods or services from or to Iran without a license.
The ITSR does include a “Publishing exemption” that authorizes US Persons to engage in any transactions “necessary and ordinarily incident to the publishing and marketing of manuscripts, books, journals, and newspapers in paper or electronic form.” (31 CFR 560.538). This exemption permits collaboration on the creation or “enhancement” of written publications, including translating, substantive editing, co-authoring or reviewing of materials, as well as the payment of royalties. The exemption does not apply if the other parties represent the Government of Iran (generally not an issue if they are from academic or research institutes in Iran) or are included in any denied parties lists. The exemption generally does not include sharing or importing of data or samples used in the publication, nor the provision of goods or services not necessary and ordinarily incident to publishing and marketing of publications, such as legal, accounting, design, or consulting services.
The ITSR also permit transactions related to travel to or within Iran, as well as the export or import of “informational materials.” Informational materials include “publications, films, posters, phonograph records, photographs, microfilms, microfiche, tapes, compact disks, CD ROMs, artworks, and news wire feeds.” Check with the Export Control office if you think your activities may fall within this exemption.
For more extensive information, please refer to: