Case No. IA-2015-318293-1
[ ]
Director
Office of Research Security Mississippi State University
P.O. Box 1983
Mississippi State, MS 39762
Dear Mr. [ ]:
This is in reply to your correspondence dated April 7, 2015 (the “Application”), to the Office of Foreign Assets Control (OFAC) seeking interpretative guidance concerning Mississippi State University’s responsibilities under the Iranian Transactions and Sanctions Regulations 31 C.F.R. Part 560 (ITSR) as it applies to visiting students from Iran.
Section 560.505 of the ITSR authorizes activities and services related to certain nonimmigrant and immigrant categories. Persons otherwise eligible for non-immigrant classification under categories including, but not limited to, F (students), J (exchange visitors), and M (non-academic students) are authorized to carry out in the United States those activities for which such a visa has been granted by the U.S. State...
1) It is not entirely clear what the applicant university was concerned about, but OFAC’s guidance in this generally limited to a rote recitation of portions of 505.560 of the ITSR and Iran General License (No. G). The one notable statement contained in the guidance is “[i]t is the responsibility of the university to verify that visiting students are pursuing coursework as authorized by the Department of State.”
We are not aware of any other guidance document that contains a similar statement. There is, however, nothing entirely surprising about it. A U.S. person university is only authorized to provide educational services to a person “ordinarily resident” in Iran to the extent that the person “ordinarily resident” in Iran is carrying out the activities in the U.S. for which the...