Case No. IA-2016-328723-1

Date issued: Jan. 10 2017

You've hit a wall. Sign in if you have an account, or learn more about TURBOFAC and subscription options.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (1365 words)

Notes:

1) BACKGROUND

This letter constitutes a notable cobbling together of licenses and exemptions to conclude that no license is required for activities that might otherwise appear to require a license.

First, note that the applicant (a U.S. person) asks about organizing and conducting a tour “participated in by various United States universities, colleges, and English language centers with the purpose of recruiting Iranian students to their schools”. Of note here is that the “English language centers” at issue here are presumably not degree granting institutions (they are not “universities” or “colleges”), but are instead of a type of which enrollment can qualify one for an F-1 student visa. See e.g. https://www.languageinternational.com/usa-student-visa-requirements - “For full-time courses (more than 18 hours of classes per week), [] students must apply for an F-1 student visa…”. In addition, note that OFAC has, in the...