Working with Iranian Collaborators

Guidance on Working with Iranian Collaborators

Update: In August 2026, OFAC suspended General License G and certain educational and conference-related authorizations under the Iranian Transactions and Sanctions Regulations (ITSR). As a result, educational services, online instruction, academic exchanges, conferences, and similar activities involving individuals located in Iran or, in some circumstances, individuals outside Iran who are ordinarily resident in Iran may require additional review.

Temporary Notice (Expired): OFAC issued General License BB to authorize the wind-down of certain activities previously authorized under suspended Iran-related general licenses through September 8, 2026. General License BB expired on September 8, 2026. Individuals with questions about activities undertaken during the wind-down period or unresolved matters should contact OSPRI.

This guidance is intended to address common questions. 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. Admission, visa eligibility, and entry into the United States are governed by applicable U.S. immigration requirements and current visa and entry restrictions. Students should work with the appropriate UCCS international student office regarding immigration and visa questions.

Once a student from Iran receives the appropriate visa and is physically present in the United States, they may generally enroll in UCCS courses.

Separate U.S. export-control requirements may apply when Iranian students participate in research involving controlled technology, source code, technical data, equipment, or software. Depending on the circumstances, access may require a license or other authorization. Contact Michael Sanderson, the Export Control Officer, with questions.

Can I work with former students or others who live in Iran, or are ordinarily resident in Iran?

It depends.

Additional review may be required for educational services, online instruction, mentoring, academic exchanges, conferences, workshops, and other activities involving individuals physically located in Iran, or, in some circumstances, individuals who are ordinarily resident in Iran. Recent OFAC actions suspended several authorizations that universities have historically relied upon for certain educational and conference-related activities. Faculty should consult Michael Sanderson before beginning or continuing such activities.

If the research involves export-controlled technology, source code, technical data, equipment, or software, significant restrictions may apply and a BIS, OFAC, or other authorization may be required. Check with OSPRI before sharing controlled or nonpublic technical information, providing substantive services, or beginning the collaborative activity. 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 U.S. Department of Treasury’s Office of Foreign Assests Control (OFAC). OFAC enforces the Iranian Transactions and Sanctions Regulations (ITSR; 31 CFR 560). The ITSR broadly restrict the importation of goods and services from Iran and the exportation, re-exportation, sale, or supply of goods, technology, or services to Iran or the Government of Iran, unless the activity is exempt or otherwise authorized.

The ITSR contains an exemption for certain information and informational materials and a separate authorization under 31 CFR § 560.538 for transactions necessary and ordinarily incident to publishing written publications. Faculty should not assume that research collaborations, educational services, mentoring activities, workshops, or conference participation are covered by the informational-materials exemption or publishing authorization merely because a publication may ultimately result. 

Check with OSPRI if you think your activities may fall within these provisions.

When to contact Export Controls?

U.S. sanctions and export control laws may restrict certain activities involving Iran, the Government of Iran, sanctioned parties, or certain goods, technology, software, and services. Whether an activity is permitted can depend on the location of the parties, the nature of the activity, the technology involved, and whether an exemption or authorization applies.

Please contact the UCCS Export Control Officer before proceeding with activities such as:

  • providing educational, consulting, research, mentoring, or other services to individuals or organizations in Iran;
  • sending goods, software, technology, unpublished research information, or other items to Iran;
  • receiving goods or services from Iran;
  • conducting research, teaching, conferences, workshops, surveys, or other university activities in Iran;
  • collaborating with an Iranian institution or other entity where sanctions may apply; or
  • providing access to export-controlled technology or technical information when a license or other authorization may be required.

Additional Resources