Case No. IA-2022-955459-1 [Application Included]

Date issued: Sep. 09 2022

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TURBOFAC Commentary (304 words)

Notes:

1) The applicant U.S. person university says that it has two students, one “would interview women who attend an Islamic ritual of mourning known as Muharram…[and]…speak with women about their participation in the ritual” (no financial compensation would be provided to participants), and the other would “interview authors of Farsi language textbooks for their dissertation” and “attend Farsi courses through the “, which is related to Tehran University” but without actually enrolling at the university. The university notes that OFAC’s 2003 guidance stating that “conduct of surveys and interviews in Iran constitutes a prohibited export of services to Iran” was live on OFAC’s website (030424-FACRL-IA-03).

OFAC responds by confirming that Iran GL G covers the Farsi courses through the authorization to “participate in educational courses at the graduate level…at Iranian universities in...