Activites with Iran

OFAC maintains a comprehensive sanctions program against Iran pursuant to the Iranian Transactions and Sanctions Regulations (ITSR), among other rules, executive orders, and policies. Additionally, the U.S. Department of State has designated Iran as a state sponsor of terrorism. These regulations and designations place significant restrictions on the interactions the UF community can have with Iran, its people, and its businesses. Additionally, Florida law prohibits the use of any university funds in support of travel to Iran.

In general, the following restrictions apply to all UF activities with Iran:

    • Cannot use any UF funds to support travel expenses for travel to Iran (includes UF Foundation, gift, start-up, college/departmental, or sponsored research funds);
    • Cannot attend or present at a conference in Iran without an OFAC license. It can take up to six months or more to obtain an OFAC license for Iran. Plan ahead!

– This license requirement applies regardless of the topic of the conference and regardless of whether the information presented is within the public domain.

The chart below lists specific examples of activities with Iran that are prohibited or are allowable under a general license. Before traveling to or collaborating with Iran, review the chart below, contact the Division of Research Compliance to seek approval for your planned activities, and register your travel with the UF International Center. The Division of Research Compliance also can assist you in seeking an OFAC license.

Prohibited Transactions

Action Description Regulatory Source
Prohibited Importation of Goods or Services from Iran Except as otherwise authorized (e.g., pursuant to a license issued by OFAC), importation into the United States of any goods or services of Iranian origin or owned or controlled by the Government of Iran, other than information and informational materials, is prohibited.

Example: accepting samples or data shipped from Iran for testing or analysis.

31 C.F.R. § 560.201

Prohibited Exportation, Reexportation, Sale, or Supply of Goods, Technology, or Services to Iran

Except as otherwise authorized, a United States person cannot export, reexport, sell, or supply any goods, technology, or services to Iran or the Government of Iran.

Note that OFAC broadly construes “services.” Examples of providing a service might include:

  • Attending an academic conference in Iran;
  • Presenting at an academic conference in Iran, even if the information presented is within the public domain;
  • Providing technical assistance to an Iranian national in Iran or an Iranian institution;
  • Providing unpublished data or research results to a person or institution in Iran;
  • Teaching or lecturing as a guest of an institution in Iran; or
  • Conducting surveys and interviews in Iran.
31 C.F.R. § 560.204

31 C.F.R. § 560.410

Prohibited use of University Funds to Support Travel-Related Activities to Iran By law in the State of Florida, UF cannot use any of its funds to implement, organize, direct, coordinate, or administer (or support those acts) activities related to or involving travel to any state sponsor of terrorism, as designated by the U.S. Department of State. Currently, Iran is designated as a state sponsor of terrorism.

Note that the prohibition is on any UF funds, including Foundation or gift funds, start-up funds, college/departmental funds, or any sponsored research award funds.

Fla. Stat. § 1011.90(6)

Fla. Stat. § 112.061(3)(e)

Authorized Transactions

Action Description Regulatory Source
Information or Informational Materials The general prohibitions described above do not apply to the importation or exportation of information or informational materials, as defined in § 560.315, whether commercial or otherwise, regardless of format or medium of transmission.

“Information or Informational Materials” includes, but is not limited to, publications, films, posters, phonograph records, photographs, microfilms, microfiche, tapes, compact disks, CD ROMs, artworks, and news wire feeds.

However, this exemption does not apply to the following:

  • Information or informational materials that are not fully created and in existence at the date of the related transactions;
  • The substantive or artistic alteration or enhancement of informational materials;
  • The provision of marketing and business consulting services; or
  • Transactions incident to the exportation of software subject to the EAR or the exportation of goods (including software) or technology for use in the transmission of any data.

31 C.F.R. § 560.210(c)

31 C.F.R. § 560.315

31 C.F.R. § 560.540

Academic Exchanges and Educational Services Academic Exchanges: Accredited graduate and undergraduate degree-granting institutions are authorized to enter into student academic exchange agreements with Iranian universities related to undergraduate or graduate education courses and to engage in all activities related to such agreements (including providing scholarships to Iranian students to attend U.S. institutions).

Educational Services:

1. U.S. academic institutions are authorized to export services:

  • Related to Iranian students (either in Iran or ordinarily resident in Iran) applying to and paying for attendance at U.S. academic institutions;
  • Related to recruitment, hiring, or employment in a teaching capacity of Iranian individuals (either in Iran or ordinarily resident in Iran) provided that the individual has the appropriate U.S. visa; and
  • To individuals in Iran (or ordinarily resident in Iran) to participate in undergraduate level online courses in the humanities, social sciences, law, or business provided that the courses are the equivalent of course ordinarily required for the completion of undergraduate degree programs in those areas 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.

2. U.S. persons who are actively enrolled in U.S. academic institutions are authorized to:

  • Participate in educational courses or noncommercial academic research at Iranian universities at the undergraduate level; or
  • Participate in educational courses at the graduate level or engage in noncommercial academic research at Iranian universities in the humanities, social sciences, law, or business at levels above the undergraduate level.

This authorization does not include exporting any goods (including software) or technology to Iran, except for technology and software designated as EAR99 or constitutes “educational information” under the EAR.

31 C.F.R. Part 560 – General License G
Peer Review & Publishing U.S. persons are authorized (subject to certain restrictions) to engage in transactions “necessary and ordinarily incident to” the publishing and marketing of manuscripts, books, journals and newspapers. This includes collaborating on the creation and enhancement of written publications and substantive editing of written publications.

This exemption does not apply if one of the parties to the transaction is the Government of Iran, which does not include academic and research institutions and their personnel.

31 C.F.R. § 560.538
Services Related to Conferences in the U.S. or Third Countries
Conferences in the U.S.

U.S. persons may import or export services, if the services are performed or provided in the U.S., for an Iranian person to participate in a public conference, performance, exhibition, or similar event, and if such services are consistent with that purpose.

Conferences in Third Countries

U.S. persons may sponsor a public conference in a third country (not U.S. or Iran) that is attended by Iranian persons provided that attendance and participation at the conference is open for the public and that the conference is not tailored in whole or in part to or for Iran or Iranian persons.

This exemption may not be used for the Government of Iran, an Iranian financial institution, or any person whose property or interests are blocked.

This exemption does not authorize the release of technology or software to an Iranian person.

31 C.F.R. § 560.554
Activities of Persons with Certain Nonimmigrant or Immigrant Classifications Persons otherwise eligible for nonimmigrant classification under category F (students), J (exchange visitors), or H (temporary worker), among other categories, are authorized to carry out in the U.S. those activities for which such a visa or nonimmigrant status has been granted by the U.S. government.

For students in the U.S. on F visas, U.S. persons may release technology and software to those students, provided that all of the following are met:

  • Such release is ordinarily incident and necessary to the educational program in which the student is enrolled;
  • The technology or software is designated as EAR99 under the Export Administration Regulations;
  • The release does not otherwise require a license from the Department of Commerce; and
  • The student is not enrolled in school or participating in the program as an agent, employee, or contractor of the Government of Iran or a business entity or other organization in Iran.

31 C.F.R. § 560.505(a), (b)

31 C.F.R. § 560.505(d)

Travel In general, when you are traveling to Iran for an authorized purpose, the resulting travel-related transactions are exempt from the Iranian Transactions and Sanctions Regulations. However, you still cannot use any UF funds in support of your travel.

Examples of exempt travel-related transactions include:

  • Transactions ordinarily incident to travel to or from any country;
  • Importation or exportation of baggage for personal use;
  • Maintenance within any country including payment of living expenses and acquisition of goods or services for personal use; and
  • Arrangement or facilitation of travel including nonscheduled air, sea, or land voyages.
31 C.F.R. § 560.210(d)
Personal Communications The prohibitions in the Iranian Transactions and Sanctions Regulations do not apply to any postal, telephonic, or other personal communication that does not involve the transfer of anything of value. 31 C.F.R. § 560.210(a)