Update: Overview of Iran Sanctions

On August 24, 2026, the Office of Foreign Assets Control (OFAC) indefinitely suspended several general licenses that previously authorized certain educational activities, educational services, academic exchanges, personal remittances, and other activities with individuals in Iran or ordinarily resident in Iran. Specifically, General License G was suspended.

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 defines foreign nationals physically located in the US as ‘US persons’.  The ITSR prohibits U.S. persons from:

  • engaging in any transaction or dealing in Iranian-origin goods or services,
  • the provision of goods and 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-US person.

To summarize, U.S. persons are prohibited from engaging in the following transactions, except where 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.

There are some exemptions:

  • Personal communications
  • ITSR Defined Authorizations are set forth in Subpart E and span Parts 560.501 through 560.556. These authorizations cover broad categories of transactions, including activities and services related to certain authorized nonimmigrant and immigrant categories (Part 560.505), telecommunications and mail transactions (Part 560.508), household goods and personal effects (Part 560.524), and transactions that are necessary and ordinarily incident to publishing activities (Part 560.538).

If the activity is not covered by an exemption, a license may be required to engage in a prohibited transaction.  The Export Control Office works with faculty, staff, and students to determine if a General License applies or to obtain an export license.

What this means for NDSU

The suspension of General License G impacted:

  • The ability of Iranian students located in Iran to take the TOEFL and other tests needed to study in the United States.
  • Students' ability to take online courses while located in Iran.
  • Universities' ability to receive certain funds from Iran after the September 8, 2026 wind-down period.
  • Faculty members' ability to teach students in Iran without obtaining a license.
  • Access to DUO from within Iran.
  • The conduct of research activities in Iran without a license.
  • Collaboration, in nearly all circumstances, with individuals located in Iran.
  • Certain publishing activities may qualify for an exception; however, the Export Control Office should be consulted in advance.

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


Keywords:
Export Controls, sanctions, OFAC, Iran, Iranian 
Doc ID:
164052
Owned by:
Kristy S. in NDSU Research and Creative Activity
Created:
2026-09-09
Updated:
2026-09-15
Sites:
NDSU Research and Creative Activity