Update: Overview of Iran Sanctions
The Iranian Transactions and Sanctions Regulations (ITSR) (31 CFR Part 560) are maintained by the federal government as part of a comprehensive sanctions program under applicable laws and regulations. OFAC considers foreign nationals physically located in the United States as "U.S. persons." The ITSR prohibits U.S. persons from:
- Engaging in any transaction or dealing involving Iranian-origin goods or services;
- Providing goods or services to Iran;
- Importing Iranian-origin goods or services;
- Directly or indirectly exporting or re-exporting any goods, technology, or services to Iran; and
- Facilitating, approving, or guaranteeing such conduct by a non-U.S. person.
To summarize these sanctions, U.S. persons are prohibited from engaging in the following transactions unless authorized through an exempt transaction, ITSR-defined authorization, general license, or specific license:
- Providing services to Iran;
- Receiving services performed by an Iranian;
- Engaging in financial transactions, directly or indirectly, with Iran;
- Engaging in transactions relating to Iranian-origin goods or services; or
- Receiving Iranian-origin goods.
Violations of OFAC sanctions may result in civil or criminal penalties for individuals.
Exceptions and Authorizations
Some exemptions and authorizations exist:
Personal Communications and Publishing Activities
Authorized transactions necessary and ordinarily incident to publishing are permitted under Part 560.538.
For qualifying publishing activities, consult the Export Control Office in advance. Examples include:
- Collaborating on the enhancement of written publications;
- Augmenting written publications;
- Substantive editing; and
- Marketing activities that promote a publication.
ITSR-Defined Authorizations
- Activities and services related to certain authorized nonimmigrant and immigrant categories (§ 560.505);
- Telecommunications and mail transactions (§ 560.508); and
- Household goods and personal effects (§ 560.524).
Licensing
A license may be required to engage in an otherwise prohibited transaction. The Export Control Office will work with faculty, staff, and students to determine whether a general license applies or whether a specific license application is necessary.
What this means for NDSU
Students with a current and valid U.S. F-1 or J-1 visa can generally continue their approved coursework, attend classes, and participate in their current academic programs.
However, recent sanctions changes have increased the risks of traveling outside the United States.
The suspension of General License G impacted:
- The ability of Iranian students located in Iran to take the TOEFL and other examinations required for study in the United States;
- Students' ability to take online classes while physically located in Iran;
- Universities' ability to receive certain funds from Iran;
- The sending or receiving of personal remittances to or from Iran. However, payment of tuition from a U.S. bank account remains permissible;
- Faculty members' ability to teach, lecture, mentor, advise, or otherwise provide educational services while physically located in Iran;
- Access to Duo while located in Iran;
- The ability to conduct research in Iran without a license;
- Faculty members' ability to develop curriculum or course materials while physically located in Iran without a license;
- Participation in video calls, conferences, or workshops while located in Iran without a license;
- Collaboration, in nearly all circumstances, with individuals located in Iran; and
- The transmission of controlled information or technology to an Iranian citizen, regardless of location.
Outside References:
Iran General License G Suspended Indefinitely (August 24, 2026)
U.S. Treasury Issues Iran General License D-2 to Increase Support for Internet Freedom
§ 560.538 Authorized transactions necessary and ordinarily incident to publishing.