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Case No. [IA-2023-1021671-1]
University of Illinois Chicago
1737 W. Polk St.
310 AOB
Chicago, IL 60612
Attn: Patricia Pfister, Export Control Compliance Officer
Dear Ms. Pfister:
This responds to your application dated February 2, 2023, to the Office of Foreign Assets Control (OFAC), requesting an interpretive guidance or alternatively an authorization for the University of Illinois Chicago (UIC) to hire Dr. Mousa Karimi, a citizen of Iran, currently residing in Canada, as an adjunct professor in the Department of Electrical and Computer Engineering (the “Department”), to teach, remotely from Canada, an undergraduate course titled, “Analog and Mixed-Signal Integrated Circuits” (ECE 468), for the period of January 9, 2023 - May 15, 2023.
According to the application, Dr. Karimi has lived in Canada since 2018, and [ ]. Dr. Karimi is currently employed as a...
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1) The applicant university asks for authorization to hire a citizen of Iran, currently residing in Canada, to teach a class “remotely from Canada”. The applicant states that the Iranian citizen “has lived in Canada since 2018” (the application was made in 2023), and that he “provided to [the U.S. university] the documentation demonstrating his Quebec permanent residency status”. OFAC notes that “Iranian-origin services [the importation of which his prohibited] include services performed outside Iran by a citizen. national or permanent resident of Iran who is ordinarily resident in Iran.”
2) OFAC concludes that “[a]s long as [the citizen of Iran] is ordinarily resident in Canada, or any other country outside Iran, he would not be considered to be ‘ordinarily resident in Iran’ for purposes of the ITSR.” This is a...