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 physically located in Iran may require additional review.

Temporary Notice: OFAC has issued General License BB authorizing the wind-down of certain activities previously authorized under suspended Iran-related general licenses through September 8, 2026. Individuals currently engaged in potentially affected activities should contact OSPRI as soon as possible.

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 the appropriate visa and is physically present in the United States, they may generally enroll in UCCS courses.

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.

Additional review may be required for educational services, online instruction, mentoring, academic exchanges, conferences, workshops, and other activities involving individuals physically located 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 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.” The publishing exemption appears to remain available under 31 CFR 560.538 for qualifying publishing activities. However, it does not apply if the Iranian parties represent the Government of Iran or are included in any denied parties lists. Faculty should not assume that research collaborations, educational services, mentoring activities, workshops, or conference participation are covered by the publishing exemption merely because a publication may ultimately result. 

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, lecturing, mentoring, advising students, or providing educational services to persons located in Iran without applicable authorization. 
    • 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