The current Iranian Transactions and Sanctions Regulations (ITSR) 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). The U.S. sanctions imposed against Iran are extensive and restrictive. It is critical that faculty, staff and students wishing to travel to Iran or engage with an Iranian entity (including a university in Iran) consult with Lehigh's Export Control Officer prior to engaging in the activity.
Note: this guidance is not intended to be all-inclusive; certain restrictions may apply depending on the specific details of a given situation. Consult with Lehigh's Export Control Officer for more specific guidance.
(This guidance has been adapted with permission from Cornell's Iran Sanctions Guidance Document)
Iran Sanctions
Lehigh faculty, staff and students may not engage in 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- E.g.: Providing unpublished data or research results to a person or institution in Iran; conducting surveys and interviews inside Iran; teaching or lecturing as a guest of an institution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
- This includes transactions with a third party where we have reason to believe that the goods, technology or services are ultimately intended for Iran and/or 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, regardless of their physical location.
- Providing access to specific types of information or informational materials:
- Information or materials not fully created and in existence at the date of the export controlled transaction (i.e. cannot pay in advance for something not yet completed).
- Alterations of these materials or information.
- Consulting services related to these materials.
- Software subject to the Export Administration Regulations. Note: open source software that exists in the public domain (such as code published in an academic journal, or in a public code repositiory) is not subject to the EAR.
The following activities may be permissible without the need for a license or general authorization:
- Personal communications that do not involve the transfer of anything of value.
- Providing humanitarian donations (food, clothing and medicine).
- Providing access to information or informational materials (includes publications, digital files, films, posters, photographs, microfilms, microfiche, tapes, compact disks, CD ROMs, artwork and news wire feeds).
- Note: These items must be publicly available and not restricted by export or proprietary designations. Items available by subscription only (e.g. paid journal access) are considered publicly available.
- Travel related transactions including baggage for personal use, payment of living expenses and facilitation of travel.
In certain situations, it may be possible to engage in an otherwise prohibited activity by utilizing either a specific license or a general authorization / license. Anyone seeking to utilize any license or authorization must first engage with Lehigh's Export Control Officer prior to initiating any activity involving Iran.
Specific Licenses
Specific licenses from OFAC authorize certain prohibited activities that, on a case by case basis, are deemed to be in the interest of the US Government. These licenses require application directly to OFAC. The review of specific license applications by OFAC may take six months or longer, with no guarantee that the license will be granted at the end of the process, so individuals should plan for the process of obtaining a specific license to be time-consuming and build this timeline into their overall plan of action.
General Licenses / Authorizations
OFAC permits certain prohibited activities to be authorized without the need to obtain a specific license, with some restrictions. Contact Lehigh's Export Control Officer to confirm whether your situation qualifies for a general license or authorization prior to engaging in the activity.
- 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.
- 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.
- OFAC's Iran Sanctions page contains a comprehensive list of all general licenses and authorizations.
Iranian students (graduate and undergraduate) who are living and studying within the U.S. on a valid visa may be permitted to participate in the conduct of fundamental and publishable research, provided the following provisions are true:
- The student(s) will not have access to, or be permitted to work on, research involving any controlled technology or technical data, as defined under the Export Administration Regulations (EAR) or the International Traffic in Arms Regulations (ITAR).
- For sponsored research: the sponsor has not imposed any restrictions and/or preapproval requirements for the involvement of foreign nationals in research.
- The conduct of the research does not involve "Use" of any potentially controlled technology. "Use" is defined as an individual having sufficient access to technology or information which would permit all six of the following activities with the technology: operation, installation (including on-site installation), maintenance (checking), repair, overhaul and refurbishing.
- For labs operating under a Technology Control Plan (TCP): all necessary restrictions on access to export controlled or otherwise restricted information has been fully implemented and documented prior to the student(s) being permitted to engage in research activity within the lab.