Case No. IA-18073
[ ]
Export Compliance Officer
Office of Research Administration and Advancement
The University of Maryland
3112 Lee Building
College Park, MD 20742-5141
Dear [ ]:
This is in response to your letter dated December 19, 2011 (the "Application"), to the U.S. Treasury Department's Office of Foreign Assets Control ("OFAC"), requesting authorization to hire an Iranian citizen, [ ] as a Research Associate in the University of Maryland ("UMD") College of Computer, Mathematical and Physical Sciences, Department of Computer Science. You indicate that [ ] will be working under a two-year grant from the Office of Naval Research for Efficient Algorithms for Strategic Problems in Network Design. You have further indicated that you have applied for a J-1 exchange visitor visa for [ ].
Unless otherwise exempted or licensed, the Iranian...
1) BACKGROUND
The application specifies a few things that make OFAC’s response more meaningful than it would otherwise be. First, note all redactions are of the name of the particular Iranian at issue (as confirmed by the University of Maryland in the cover letter at p. 4 of the native .PDF file).
Second, note that the particular Iranian at issue here was, at the time of the request for guidance, ordinarily resident in Iran and actually present in Iran (“[redacted name] currently resides in Iran” – p. 6). In other words, it was not the case that the Iranian was “ordinarily resident” in Iran but in the United States or some other country on a visa described at 560.505 of the ITSR.
Third, note that a “Research Associate,” as...