Export Controls: Iran Sanctions Guidance Document

It is critical that faculty, staff and students wishing to travel to Iran or engage with an Iranian entity, consult with Cornell’s Export Control Office.

The existing U.S. sanctions imposed against Iran are the strictest ones to date. The current Iranian Transactions and Sanctions Regulations (ITSRs) were fully imposed on November 5, 2018 and are administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). It is critical that faculty, staff and students wishing to travel to Iran or engage with an Iranian entity, consult with Cornell’s Export Control Office prior to engaging in the activity.1

Prohibitions

Cornell faculty, staff and students may not engage 2in any of the following activities which are expressly prohibited under the ITSR:

  • All imports of Iranian goods or services into the United States or to a U.S. Person.
    E.g.: Accepting samples shipped from Iran for testing or analysis; accepting payment from an Iranian entity; attending a class, lecture, workshop or conference in Iran.
  • The export, sale or supply from the United States or by a U.S. Person (wherever located), of any goods, technology or services to Iran.
    E.g.: Providing unpublished data or research results to a person or institution in Iran; Conducting surveys and interviews inside Iran; Teaching or lecturing as a guest of an institution in Iran
    • The above bullet includes transaction with a third party where we have reason to believe that the goods, technology or services are ultimately intended for Iran.
    • The above bullet includes transactions with a third party where we have reason to believe that the goods, technology or services will be used in the production of or the incorporation into any goods, technology or services to be supplied to Iran
  • Any transaction involving goods or services of Iranian origin.
  • Any investment in Iran.
  • The transmission of controlled information or technology to an Iranian citizen wherever located.

Exempt Transactions

  • Personal communications that do not involve the transfer of anything of value.
  • Humanitarian donations (food, clothing and medicine).
  • Information or informational materials (includes publications, digital files, films, posters, photographs, microfilms, microfiche, tapes, compact disks, CD ROMs, artwork and news wire feeds).
    • Must be publically available and not restricted by export or proprietary designations.
    • Information or informational materials that are NOT exempt:
      • Information or materials not fully created and in existence at the date of the transaction (i.e. cannot pay in advance for something not yet completed).
      • Alterations of the information or materials.
      • Consulting services related to the materials.
      • Software subject to the Export Administration Regulations.
  • Travel related transactions including baggage for personal use, payment of living expenses and facilitation of travel.
    • Note that this exemption does NOT authorize the trip itself. It only authorizes transactions normally incident to a trip that has been pre-approved via a license.

Licenses and Authorizations

While the ITSR imposes a number of prohibitions on dealings with Iran, it may still be possible to engage in an otherwise prohibited activity by utilizing either a specific or general license.

Specific Licenses

It may be possible to engage in an otherwise prohibited transaction, if a specific license is obtained from OFAC. Specific license applications are reviewed by OFAC on a case by case basis. To apply for a specific license, please contact Cornell’s Export Control Officer. Please note that a specific license can take six months or more to be reviewed and approved by OFAC, so allow plenty of time when planning your activity.

Authorizations and General Licenses

OFAC has issued authorizations and general licenses in order to authorize some otherwise prohibited activities. The activities described in the authorizations and general licenses are approved without the need to apply for a specific license.3 Please contact Cornell’s Export Control Office prior to utilizing one of the authorizations below, as some restrictions may apply. 

  • Recipients of visas are authorized to carry out those activities for which such visa has been granted. Certain transactions related to the filing and preparation of visa applications are also authorized.
  • Personal telecommunications and mail transactions are authorized, as long as nothing of value is transmitted.
  • Certain transactions related to intellectual property protection are authorized (e.g., filing for patent protection).
  • Collaborating on the creation and enhancement of written publications is authorized assuming the transaction does not involve the Government of Iran or an agency thereof.
    • The collaboration may involve only transactions that are necessary and ordinarily incident to the creation and publication.
    • Does not authorize development, production or design of software or any controlled item or technology.
  • The exchange of personal communications over the Internet, such as instant messaging, chat and email and social networking is authorized, provided that such services are publicly available and at no cost to the user.4
  • Accredited U.S. academic institutions may engage in the following activities with respect to undergraduate programs in the humanities, social sciences, law and business:
    • Recruit, hire and employ faculty and staff who are ordinarily resident in Iran.
    • Recruit, enroll and educate students who are ordinarily resident in Iran.
    • Recruit individuals ordinarily resident in Iran, such as scholars, artists, performers, speakers, alumni, and students, to participate in events, such as conferences, lectures, film series, research workshops, exhibitions, theatrical and musical performances, and continuing education courses. U.S. undergraduate institutions are authorized to provide compensation, including honoraria, to such individuals.
  • General License G:
    • Authorizes U.S. academic institutions to enter into student exchange agreements with universities located in Iran.
    • Authorizes certain educational services, including:
      • Those necessary to the filing and processing of applicants and the acceptance of payments for submitted applications and tuition from or on behalf of Iranian citizens.
      • Those related to the recruitment and employment in a teaching capacity of Iranian citizens who are already employed in a teaching capacity at an Iranian university, provided the appropriate visa is granted.
      • Participation in educational courses or engagement in non-commercial academic research at Iranian universities at the undergraduate level by U.S. persons who are actively enrolled in U.S. academic institutions.
      • Participation in educational courses or engagement in non-commercial academic research at Iranian universities at the graduate level in the areas of humanities, social sciences, law or business.
      • The participation by Iranian citizens in undergraduate level online courses provided by U.S. academic institutions in the fields of the humanities, social sciences, law or business provided that the courses are of the type ordinarily required for the completion of undergraduate degree programs in the humanities, social sciences, law or business, or are introductory undergraduate level science, technology, engineering, or math courses ordinarily required for the completion of undergraduate degree programs in the humanities, social sciences, law or business.
  • General License D-1:
    • Authorizes the export (including for travel purposes) to Iran of fee-based services incident to the exchange of personal communications over the Internet such as instant messaging, chat, email, social networking, sharing of photos, web browsing and blogging.
      • Authorizes the export to Iran of fee-based software designated as EAR99 or 5D992.c, that is necessary to enable services incident to the exchange of personal communications over the Internet such as instant messaging, chat, email, social networking, sharing of photos, web browsing and blogging.
    • The following are specifically authorized for export (including travel) to Iran subject to some restrictions5:
      • Standard mobile phones, PDAs, SIM cards and most mobile operating systems6
      • Standard laptops, tablets and personal computing devices
      • Some anti-virus software
      • Standard VPN software
  • 1. The lists of prohibitions and authorizations contained in this document are not all-inclusive. In addition, certain restrictions may apply.
  • 2. Without confirmation from the Export Control Office that a license or general authorization applies.
  • 3. U.S. banks may only process transfers of funds to or from Iran, or for the direct or indirect benefit of persons in Iran, if the transfer arises from, and is ordinarily incident and necessary to give effect to, an underlying transaction that has been authorized by a specific or general license and the payment does not involve debiting or crediting an Iranian account or involve an entity on a government restricted party list.
  • 4. Also see General License D-1.
  • 5. Contact the Export Control Office for confirmation.
  • 6. Taking your laptop or mobile device when you travel significantly increases the possibility of data and identity theft. If you are traveling to high-risk countries or countries with technological restrictions, a free travel loaner system will make travel easy while helping secure your data. Visit https://it.cornell.edu/highrisktravel to learn about Cornell’s loaner device program.