Case No. IA-2015-318293-1

Date issued: Mar. 13 2016

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TURBOFAC Commentary (261 words)

Notes:

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...