OFAC Sanctions and Distance Learning Guidance for the University of Rochester Community

The United States Treasury Department’s Office of Foreign Assets Control (OFAC) administers several sanctions programs.  For a complete list of OFAC sanctions please review:  OFAC Sanctions Programs and Country Information.¹  

Comprehensive OFAC sanctions apply to Cuba, Iran, Syria, North Korea and the Crimea region of Ukraine. 

Be mindful of applicable export control and OFAC restrictions when planning to provide distance learning services (e.g. online courses) to someone outside the U.S.

Note that the University may host and provide educational services to students and scholars in the U.S. from countries/regions subject to OFAC sanctions, provided such activities are in alignment with the respective individual’s visa.²  

Syria, Crimea region of Ukraine, North Korea
A specific license is required from OFAC prior to providing distance education to someone in Syria, the Crimea region of Ukraine and/or North Korea. 

Please reach out to the University’s Export Control Officer and Global Engagement about seeking an OFAC license well in advance of any anticipated remote educational activities with someone in Syria, Crimea and/or North Korea. 

Iran
General License G of the Iran OFAC sanctions allows certain remote educational activities: 

“U.S. academic institutions, including their contractors, are authorized to export services:
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(iii) to individuals located in Iran, or located outside Iran but who are ordinarily resident in Iran, to sign up for and to participate in undergraduate level online courses (including Massive Open Online Courses, coursework not part of a degree seeking program, and fee-based courses) provided by U.S. academic institutions in the humanities, social sciences, law, or business provided that the courses are the equivalent of courses ordinarily required for the completion of undergraduate degree programs in the humanities, social sciences, law, or business, or are introductory undergraduate level science, technology, engineering, or math courses ordinarily required for the completion of undergraduate degree programs in the humanities, social sciences, law, or business.”  (emphasis added)

• In other words, if your class is both:
• at the undergraduate level AND
• in the humanities, social sciences, law, or business (provided the class is the equivalent of one ordinarily required for the completion of an undergraduate degree program in the humanities, social sciences, law, or business); or is an introductory science, technology, engineering, or math class (provided the class is ordinarily required for the completion of an undergraduate degree program in the humanities, social sciences, law, or business)

then you do not need specific permission from the U.S. Government to provide your educational activities.

• If your class is above the undergraduate level, or is at the undergraduate level but does not fall within the specific subject matter requirements of General License G (as summarized in the two bullet points above), then please reach out to the University’s Export Control Officer and Global Engagement about seeking an OFAC license well in advance of any anticipated remote educational activities with someone in (or ordinarily resident in) Iran. 

Cuba
Section §515.565(x) of OFAC’s Cuban Assets Control Regulations allows:

“…persons subject to U.S. jurisdiction, including U.S. academic institutions and their faculty, staff, and students, are authorized to engage in transactions, including the travel-related transactions set forth in §515.560(c), that are directly incident to the following activities…
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(x) Provision of Internet-based courses, including distance learning and Massive Open Online Courses, to Cuban nationals, wherever located, provided that the course content is at the undergraduate level or below;” (emphasis added)

• If your class is at the undergraduate level or below, you do not need specific permission from the U.S. Government to provide your educational activities.
• If your class is above the undergraduate level, then please reach out to the University’s Export Control Officer and Global Engagement about seeking an OFAC license well in advance of any anticipated remote educational activities with someone in Cuba. 

 

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