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Michigan State University Export Control & Trade Sanctions

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U.S. Sanctions on Iran 

UPDATE:  On August 24, 2026, the U.S. Treasury Department, Office of Foreign Assets Control (OFAC) suspended several general licenses that previously authorized certain educational activities, educational services, academic exchanges, personal remittances, and other activities with individuals in Iran and individuals ordinarily resident in Iran. Activities that were previously permissible under the suspended OFAC general licenses must be suspended no later than September 7, 2026. 

Due to these updates, U.S. academic institutions are no longer authorized to offer online courses to individuals in Iran; process applications, accept tuition payments, or issue scholarships for individuals located in Iran; recruit, hire, or employ in a teaching capacity individuals currently teaching at Iranian universities; or facilitate, sponsor, or support the participation of Iran residents in conferences or similar events without a specific license from OFAC. 

MSU faculty, students, and staff, who are ordinarily residents of Iran, but who are already in the U.S. with a valid immigrant or nonimmigrant status in one of the categories specifically enumerated in the General License under 31 CFR 560.505, are not affected by this change. They may continue to participate in the activities for which their visa was issued or other status granted, including receiving tuition support, salary, or other authorized payments, provided those transactions do not involve restricted parties or prohibited financial channels pursuant to 31 CFR 560.505. 

Contact MSU’s Office of Export Control & Trade Sanctions (ECTS) at export@msu.edu for questions about whether a general license applies or assistance with obtaining a “specific” OFAC license. 

BACKGROUND: The U.S. federal government maintains comprehensive sanctions and embargoes on Iran pursuant to various laws and regulations, including the Iranian Transactions and Sanctions Regulations, 31 C.F.R. Part 560 (the “ITSR”). The ITSR generally prohibits U.S. Persons from:    

  1. Engaging in any transaction or dealing in Iranian-origin goods or services;  

  1. Providing goods and/or services to Iran;  

  1. Importing Iranian-origin goods or services;   

  1. Directly or indirectly exporting or re-exporting any goods, technology, or services to Iran; and 

  1. Facilitating, approving, or guaranteeing such conduct by a non-U.S. person.    

Contact MSU’s Office of Export Control & Trade Sanctions (ECTS) for questions about whether a general license may apply or for assistance with obtaining a “specific” OFAC license. 

 

FREQUENTLY ASKED QUESTIONS: 

  1. Am I able to teach MSU students who are in the United States when I am in located in Iran? No, not without obtaining a specific OFAC license. Teaching classes from Iran is importing academic services from Iran to the United States in violation of the Iran sanctions under the ITSR.  

 

  1. Can I take MSU online courses while I am located in Iran? Not currently without a specific OFAC license. OFAC suspended General License G that previously authorized the export of educational services for undergraduate level courses in humanities, social science, law, or business; and introductory undergraduate level science, technology, engineering, or math courses required for the completion of undergraduate level humanities, social science, law, or business degrees.   

 

  1. Can I conduct research while I’m in Iran?  No, not without obtaining a specific OFAC license. Conducting research from Iran is considered to be importing research services from Iran to the U.S. in violation of the Iran sanctions under the ITSR.  

 

  1. While in Iran, can I access my MSU email account and work on developing curriculum for courses I will teach in the United States?  While personal communications are exempt, performing work and exchanging work-related communications while located in Iran will likely require a specific OFAC license. Performing work for MSU while you are located in Iran requires a specific OFAC license.  

 

  1. How else could the Iranian Transactions and Sanctions Regulations (ITSR) impact MSU faculty, students, and staff?  

  • Under the Export Control Regulations, MSU personnel should not take university equipment outside the country to an OFAC-sanctioned country without coordinating with MSU’s Office of ECTS (export@msu.edu) as doing so may be an export violation. 

  • MSU personnel cannot attend conferences in Iran, in person or virtually, without a specific license.  Please reach out to MSU’s Office of ECTS for more information.       

  • While there some general license exceptions available for publishing activities in Iran, such as work on a paper outside of the U.S., please coordinate with MSU’s Office of ECTS in advance to see if a specific license is required.  

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Export Control & Trade Sanctions

4000 Collins Rd.
Lansing, MI 48910
export@msu.edu
517-432-4499

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