OFAC extended the authorization of certain exports of educational services and software from U.S. accredited graduate and undergraduate degree-granting academic institutions (and their contractors) to eligible Iranian students who have been granted non-immigrant visas by the U.S. Department of State, but are not physically present in the U.S. due to COVID-19. New General License ("GL") M-1, which replaces and supersedes GL M, extends the authorization from September 1, 2021, to September 1, 2022.
Specifically, GL M-1 authorizes activities related to:
- the delivery of software to covered Iranian students, if such software is not subject to Export Administration Regulations ("EAR") or is classified as EAR99; and
- the delivery of online educational services to covered Iranian students in connection with graduate level courses that (i) match those that are mandatory for a humanities, social sciences, law or business graduate degree program or (ii) are introductory level courses in science, technology, engineering or math.
In updated FAQ 853, OFAC provided additional explanation around those educational activities permitted under GL M-1.
OFAC stated that GL M-1 does not authorize exports to the Iranian government or any individual with property or interests in property that are blocked under OFAC regulations.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
