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[Case No]. IA-2013-302015-1
Ms. Brittany Whiting
Export Control Officer
Office of Research
University of California, San Diego
Torrey Pines North, Level 3
West 9500 Gilman Drive #910
La Jolla, CA 92093-0934
Dear Ms. Whiting:
This responds to your requests of April 29, 2013, and November 20, 2013 (collectively, the “Application”), to the Office of Foreign Assets Control (“OFAC”), on behalf of the University of California, San Diego (the “University”), requesting authorization to allow Dr. Babak Rahimi, an associate professor of communication, culture, and religion in the University’s Department of Literature, to conduct cultural and academic field research in Iran on the influence of Information and Communications Technologies (“ICTs”) on the economic, social, political, and religious spheres of life in Iran. As stated in the Application, Dr. Rahimi plans to make multiple...
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1) Compare LICENSE No. IA-2015-316156-1 (similar). This specific license (with associated application) illustrates OFAC's favorable licensing policy for academic work in Iran, and at the same time illustrates the limits of the scope of the GL (560.538) for "transactions necessary and ordinarily incident to publishing". As with LICENSE No. IA-2015-316156-1, OFAC draws a distinction between “collaboration” with persons directly involved with publications, like editors and co-authors, and the subjects of research, such as the "ordinary Iranians" at issue here.
2) While OFAC acknowledges that the "personal laptop" would not require authorization in light of GL D-1, it is notable that OFAC authorizes, "to the extent authorization is required, exporting to Iran and importing into the United States an EAR99 recording device for the purpose of collecting data for [the] research" at issue. It is possible that the “to the extent authorization...