PRINT
Case No. IA-2016-328723-1
[
]
Dear Mr. [ ]:
This responds to your request dated March 28, 2016 and supplemented November 1, 2016 (collectively the "Application"), submitted on behalf of the [ ], Inc. to the Office of Foreign Assets Control (OFAC), requesting authorization to organize and conduct an educational tour (the "Tour") participated in by various United States universities, colleges, and English language centers with the purpose of recruiting Iranian students to their schools. The Tour will visit two Iranian cities, Tehran and Isfahan, from February 24-28, 2017 and in each city participants will attend fairs consisting of Iranian university representatives and Iranian students.
The Iranian Transactions and Sanctions Regulations 31 C.F.R. Part 560 (ITSR), generally prohibit the exportation, reexportation, sale, or supply of any goods, technology, or services, directly or...
Click the appropriate link below for access to this file.
Click the appropriate link below for access to this file.
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...