On August 24, the Treasury Department temporarily loosened restrictions on educational services for certain Iranian students. The general license, issued by the Office of Foreign Assets Control, allowed U.S. institutions to provide online courses and educational software to Iranian students who were granted student visas but were not physically in the United States due to the COVID-19 pandemic. Eligible online courses included those "required for the completion of graduate degree programs in the humanities, social sciences, law, or business” or related introductory courses, the Treasury said.
Companies were still prohibited from selling courses or educational software to the Iranian government or any Iranian under U.S. sanctions. The authorization is due to expire on September 1, 2022. The following is the Treasury authorization.
Treasury's Office of Foreign Assets Control on August 24:
Authorizing the Exportation of Certain Graduate Level Educational Services and Software
(a) Except as provided in paragraph (c) of this general license, accredited graduate and undergraduate degree-granting academic institutions located in the United States (collectively, “U.S. academic institutions”), including their contractors, are authorized through 12:01 a.m. eastern daylight time, September 1, 2022, to engage in the following activities with respect to Iranian students described in paragraph (b):
(1) Online Educational Services. The provision of online educational services related to graduate educational courses, provided that the courses are the equivalent of courses ordinarily required for the completion of graduate degree programs in the humanities, social sciences, law, or business, or are introductory science, technology, engineering, or mathematics courses ordinarily required for the completion of graduate degree programs in the humanities, social sciences, law, or business, and participation in all activities related to the provision of such online educational services to Iranian students described in paragraph (b).
(2) Exportation of Software. The exportation of software to Iranian students described in paragraph (b) in order to facilitate participation in the activities authorized in (i) paragraph (a) of this general license or (ii) paragraph (b)(1)(iii) of Iran General License G, provided such software is designated as EAR99 under the Export Administration Regulations, 15 CFR parts 730 through 774 (EAR), or constitutes information or software not subject to the EAR pursuant to 15 CFR § 734.3(b)(3).
(b) Iranian students referred to in paragraph (a) are individuals located in Iran, or located outside Iran but who are ordinarily resident in Iran, who are eligible for non-immigrant classification under categories F (students) or M (non-academic students), and have been granted a non-immigrant visa by the U.S. State Department, but are not physically present in the United States due to the COVID-19 pandemic.
(c) This general license does not authorize the exportation or reexportation of any services or software to the Government of Iran or any other person whose property and interests in property are blocked pursuant to 31 CFR chapter V.
(d) Effective August 24, 2021, General License M, dated October 29, 2020, is replaced and superseded in its entirety by this General License M-1.
Note 1 to General License M-1. The importation from Iran and the exportation to Iran of information or informational materials, as defined in 31 CFR § 560.315, whether commercial or otherwise, regardless of format or medium of transmission, are exempt from the prohibitions of 31 CFR part 560. See 31 CFR § 560.210(c).
Note 2 to General License M-1. U.S. persons are authorized to engage in the exportation of certain educational services under Iran General License G, which was issued pursuant to 31 CFR part 560, and to export, reexport, and provide certain services, software, and hardware incident to personal communications under Iran General License D-1, which was issued pursuant to 31 CFR part 560.