Iran General License (No. G) - Certain Academic Exchanges and the Exportation or Importation of Certain Educational Services Authorized

Date issued: Mar. 19 2014

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TURBOFAC Commentary (693 words)

Notes:

1) The authorization at paragraph (b)(1)(iii) came on the heels of a widely publicized problem with Coursera, for-profit provider of MOOCs that, up until around 2014, had seemingly interpreted the Berman Amendment (560.210(c)) as exempting its activities from regulation under the ITSR, CACR, Syrian and Sudanese Sanctions Regulations [1]. Coursera was apparently informed that the full range of its activities (grading, students' interaction with professors, etc.) constituted the provision of services, rather than just the export of informational materials and transactions ordinarily incident to the dissemination thereof. Following the issue of this license, Coursera began to offer courses falling within the scope of the license to Iranians in Iran [2][3].

The GL applies to "U.S. academic institutions, including their...