Working with Iranian Collaborators

Guidance on Working with Iranian Collaborators

This guidance is intended to address common questions about working with students or others of Iranian citizenship. Because of the complexities of the existing U.S. sanctions imposed on Iran, we encourage you to contact Mike Sanderson, the Export Controls Officer for campus (exportcontrol@uccs.edu), with questions before the start of any collaboration.

Are there restrictions on Iranians studying in the US?

UCCS encourages collaboration and supports students from Iran. However, like all international students, Iranian students must receive a visa in order to study at UCCS.

Once a student from Iran receives a student visa, he or she may generally enroll in any courses offered by UCCS.

Due to U.S. sanctions related to Iran, Iranian students may be prohibited from working on some research projects that involve export-controlled technology or technical data without obtaining the appropriate licenses or approvals. Generally, this would occur only if the research was not intended to be published in the public domain, or if it involved access to equipment or software that is export-controlled. Contact Michael Sanderson, the Export Control Officer, if you have questions.

Can I work with former students or others who are living in Iran?

It depends.

If the research involves export-controlled technologies, there are significant limitations on working with Iranian collaborators, and licenses are difficult to obtain. Check with OSPRI before even having preliminary discussions. Export-controlled technologies are listed on the Department of Commerce Commodity Control List or the Department of State US Munitions List.

If the collaboration does not involve export-controlled technologies, there still may be restrictions imposed by the Department of Treasury’s Office of Foreign Asset Control (OFAC). OFAC enforces the Iranian Transactions and Sanctions Regulations (ITSR; 31 CFR 560). The ITSR broadly (and strictly) prohibit the importation or exportation of ANY goods or services from or to Iran without a license or documented exemption.

The ITSR does include a “Publishing exemption.” This exemption authorizes US Persons to engage in any transactions “necessary and ordinarily incident to the publishing and marketing of manuscripts, books, journals, and newspapers in paper or electronic form.” (31 CFR 560.538). However, it does not apply if the Iranian parties represent the Government of Iran or are included in any denied parties lists.

Note that this does not include research activities leading up to a publication. 

Check with OSPRI if you think your activities may fall within this exemption.

Prohibitions

UCCS faculty, staff and students may not engage in any of the following activities, which are expressly prohibited under the ITSR, without consulting with the UCCS Export Control Officer to determine if a general license or specific license may apply:

  • All imports of Iranian goods or services into the United States or to a U.S. Person.
    E.g.: Accepting samples shipped from Iran for testing or analysis; accepting payment from an Iranian entity; attending a class, lecture, workshop or conference in Iran.
  • The export, sale, or supply from the United States or by a U.S. Person (wherever located), of any 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
    • The above bullet includes transactions with a third party where we have reason to believe that the goods, technology, or services are ultimately intended for Iran.
    • The above bullet includes transactions with a third party where we have reason to believe that the goods, technology, or services will be used in the production of or the incorporation into any goods, technology, or services to be supplied to Iran
  • Any transaction involving goods or services of Iranian origin.
  • Any investment in Iran.
  • The transmission of controlled information or technology to an Iranian citizen wherever located.

Additional Resources