Case No. IA-2015-320200-1 [Application included]

Date issued: Jul. 17 2017

Last substantive commentary amendment:
Jan. 02 2024

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TURBOFAC Commentary (1594 words)

Notes:

1) This letter, which was issued over two years after the submission of the application (signaling interagency consultation), addresses a few issues of particular interest to the education industry and internet services providers alike.

2) GENERAL LICENSE G – Courses “Ordinarily Required” For Degrees in Certain Subjects

The applicant wants to include students “in Iran” in a “massive open online course [MOOC] on Caring Science.” The application notes that the university's "third-party ...responsible for technical support managing the system on which the MOOC [would] be housed [would] not allow foreign nationals from certain countries to register". This appears to refer to students from sanctioned countries. The application requests guidance as to whether the university could teach the class itself, through blogs, email, and the sharing of YouTube links. Absent an applicable exemption or authorization, OFAC would consider that to amount to...