U.S. flag

An official website of the United States government

853. Can U.S. academic institutions provide online learning services to Iranian students located outside the United States?  Can U.S. technology companies provide software and services to assist Iranian students in accessing online coursework?


General licenses issued under the Iranian Transactions and Sanctions Regulations (ITSR) authorize certain U.S. academic institutions and other U.S. persons to provide certain services and software to Iranian students.  These general licenses include:

  • General License G (GL G) authorizes accredited graduate and undergraduate degree-granting U.S. academic institutions, including their contractors, to export services to students located in Iran, or located outside of Iran but who are ordinarily resident in Iran (“Iranian students”), to sign up for and participate in certain undergraduate level online courses, notably:  (i) courses in the humanities, social sciences, law, or business that are the equivalent of courses ordinarily required for the completion of undergraduate degree programs in the humanities, social sciences, law, or business; and (ii) introductory undergraduate level science, technology, engineering, or mathematics courses ordinarily required for the completion of undergraduate degree programs in the humanities, social sciences, law, or business.  In addition, under 31 CFR § 560.405, certain transactions ordinarily incident to a licensed transaction are also authorized.  OFAC interprets 31 CFR § 560.405 to authorize certain transactions ordinarily incident to courses authorized by GL G, including the giving of assignments and testing and grading of Iranian students. 
  • Section 560.540 of the ITSR authorizes the exportation to Iran of certain services and software incident to the exchange of communications over the internet, such as instant messaging, chat and email, social networking, sharing of photos and movies, web browsing, blogging, social media platforms, collaboration platforms, video conferencing, e-gaming platforms, e-learning platforms, automated translation, web maps, and user authentication services, as well as certain cloud-based services.  OFAC interprets these authorizations to cover video conferencing software and related services, as well as educational technology software and related services, that allow students to view courses and course materials, complete tests and assignments, receive grades, participate in discussions, and other, similar course-related online activity, provided that the software meets the additional criteria of the applicable authorization.  For more guidance on 31 CFR § 560.540 of the ITSR, please see FAQs 338–348, 434–443, 1087–1089, and 1110.

To export services to Iranian students that fall outside of these authorizations, U.S. persons may apply for a specific license through the OFAC License Application Page

Please note that the general licenses summarized above do not authorize the exportation of goods (including software), services, or technology to the Government of Iran, except as authorized under 31 CFR § 560.540(a)(6), or to persons blocked under any authority administered by OFAC, including OFAC’s counterterrorism or counterproliferation authorities. 

Date Updated: May 16, 2024

Date Released
August 24, 2021