NEW: OFAC Issues Significant Restrictions on University Engagements Involving Iran
As of August 24, 2026, OFAC suspended key Iran-related general authorizations. The suspension of these general authorizations will impact university activities involving persons who are in Iran or are ordinarily resident in Iran as well as Iranian institutions.
As of August 24, 2026, OFAC suspended key Iran-related general authorizations. The suspension of these general authorizations will impact university activities involving persons who are in Iran or are ordinarily resident in Iran as well as Iranian institutions.
Many university activities involving persons who are ordinarily residents in Iran, or Iranian institutions, will no longer be covered by a general authorization. Activities that were previously permissible, but are no longer, must be suspended and now require a specific license issued by OFAC before they can be continued. Currently, there is a presumption of denial for any such OFAC specific license.
These now-prohibited activities include:
- Academic and educational services (including admissions and enrollment)
- Recruitment, hiring and employment activities
- Enrollment and participation in online courses
- Research collaborations and academic exchanges
- Conferences and professional meetings
- Athletic programs and competitions
- Other university-sponsored engagements involving individuals in Iran
These activities have been prohibited through the suspension of five specific Iran-related authorizations under the Code of Federal Regulations (CFR):
- 31 CFR 560.544, which authorized certain educational activities by U.S. persons in third countries
- 31 CFR 560.550, which authorized certain noncommercial, personal remittances to or from Iran
- 31 CFR 560.554, which authorized importation and exportation of services related to conferences in the United States or third countries
- Iran General License F (pdf), which authorized certain services in support of professional and amateur sports activities and exchanges involving the United States and Iran
- Iran General License G (pdf), which authorized certain academic exchanges and the exportation or importation of certain educational services
Students, faculty or staff who are ordinarily residents of Iran, but already in the U.S. with a valid immigrant or nonimmigrant status (i.e., F, J, O, H visas as well as any other visa category identified in 31 CFR 560.505) are not affected by this change and 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 (see 31 CFR 560 505).
Before beginning or continuing any university activity involving Iranian institutions, citizens, or residents, contact the University's Export Controls office for guidance. The office can help determine whether an activity is permitted or requires special authorization from OFAC.
OFAC Sanctions
USC faculty and staff should be aware of OFAC’s sanctions as these regulations can impact research, education, travel, and other university-based activities. OFAC sanctions can apply to individuals, entities, or entire countries. This includes restrictions on sharing information or collaborating with researchers, scientists, colleagues, or students who live or work in sanctioned countries. Before engaging in research or scholarly activities with an individual in or from a sanctioned country, specific steps are required to determine if the activity can be undertaken.
Currently, five countries, Cuba, Iran, North Korea, Syria, and the Crimean region of Ukraine, are identified as posing the greatest risk. Many activities associated with academic collaborations, including but not limited to reviewing proposals, conducting surveys, editing papers, etc., are covered by these sanctions.
Special approval is NOT required to engage with faculty, staff, or students who are nationals of a sanctioned country if they are in the US under a valid visa and the activity supports their approved visa activities. Individuals from these countries should be involved only in unrestricted fundamental research that is covered by their visa.
As the regulations vary from country to country, please contact the Office of Sponsored Awards Management (SAM) before engaging in activities with government entities, organizations in, or persons who are a resident of or normally reside in one of the sanctioned countries. SAM will assist with determining if and under what circumstances the activity may be undertaken.