Sanctions & Embargoes

Iran

The U.S. federal government maintains comprehensive sanctions on Iran pursuant to various laws and regulations, including the Iranian Transactions and Sanctions Regulations, (the 鈥淚TSR鈥). Among other proscriptions, the ITSR prohibits U.S. persons from:  

  1. Importation of goods or services from Iran;
  2. Evasions; attempts; causing violations; conspiracies;
  3. Exportation, reexportation, sale, or supply of goods, technology, or services to Iran;  
    • E.g.: Providing unpublished data or research results to a person or institution in Iran; conducting surveys and interviews inside Iran; teaching or lecturing as a guest of an institution in Iran, physical shipments.
  4. Trade-related transactions with Iran; goods, technology, or services;
  5. Investment in Iran or in property (including entities) owned or controlled by the Government of Iran; and
  6. Facilitation by United States persons of transactions by foreign persons.   

Violating OFAC sanctions can result in individual criminal or civil penalties.

The ITSR includes mechanisms where transactions that are otherwise prohibited, can be exempted or authorized under certain conditions.  Among other proscriptions, the ITSR exempts transactions:

  1. Personal communications
  2. Humanitarian donations
  3. Information or informational materials
    • For purposes of this part, the term 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.
    • does not exempt from regulation or authorize transactions related to information or informational materials not fully created and in existence at the date of the transactions, or to the substantive or artistic alteration or enhancement of informational materials, or to the provision of marketing and business consulting services.
    • does not exempt or authorize transactions incident to the exportation of software subject to the Export Administration Regulations, or to the exportation of goods (including software) or technology for use in the transmission of any data, or to the provision, sale, or leasing of capacity on telecommunications transmission facilities.
  4. Travel 
    • Travel to Iran to attend or present at an open conference will require a license from OFAC. Similarly, a presentation via webinar to a live audience that includes individuals inside Iran would also require a license from OFAC.


Under issued by OFAC, Certain Academic Exchanges and the Exportation or Importation of Certain Educational Services are Authorized.

Please contact the Office of Export Controls before engaging in any activity with individuals or institutions in an OFAC sanctioned country, even if the activity is exempted or authorized under OFAC regulations.