Economic Sanctions and Embargoes
Iran: Prohibited Activities
Current U.S. sanctions and embargoes may require you to have U.S. government approval before you travel to Iran, engage in activities in Iran or in the United States with Iranian persons or entities.
Examples of activities that may be restricted are:
- Furnishing financial assistance, materials or services to an entity in Iran
- Travel to Iran with a laptop
- Research, field-work, or instruction in Iran
- Importing merchandise from Iran
- Collaborating, presenting or training individuals or entities in Iran
If you violate these rules, you may be subject to civil and/or criminal penalties. The U.S. government announced in January 2016 changes to the sanctions against Iran. It is important to understand that most of the sanctions against Iran that restrict Yale activities in Iran remain in place. Those traveling to Iran or engaging in activities with Iranian persons or entities, must contact Don Deyo, Director of Export Control Licensing, at 203-785-3817 for guidance and assistance.
*Note: Yale College students may not undertake travel to Iran that is: 1) funded by Yale; 2) awarded credit by Yale; or 3) in connection with a trip abroad by a recognized student organization, as individuals, or in groups. For more information please review Yale University’s International Travel Policy for Yale College Students available at http://cipe.yale.edu/travel-resources/travel-policy. Yale graduate and professional students should contact their Dean of Student Affairs to find out if similar restrictions apply.
A. Activities Permitted
While the U.S. government continues to enforce a comprehensive embargo of Iran, in 2014, the U.S. government issued new regulations that allow U.S. academic institutions to engage in certain educational activities with Iran. Yale faculty, staff and students may engage in the educational activities listed below without needing to apply for a specific license from the U.S. Government. However, prior to engaging in any of these activities, Yale faculty, staff, and students must contact Don Deyo, Director of Export Control Licensing, at 203-785-3817 to confirm that their activities fall into one of the exemptions listed below and to find out if additional rules may restrict their activities. The list below is not intended to be exhaustive.
1. Academic Study, Research or Teaching Activities
- Exchange Agreements: Yale departments/schools may enter into academic student exchange agreements with universities in Iran.
- Courses and Research in Iran:
- Yale faculty, students, or staff may participate in undergraduate level courses in Iran or engage in noncommercial academic research in Iran at the undergraduate level in any discipline (*however, see note above regarding Yale College student travel to Iran).
- Yale faculty, students, or staff students may participate in graduate level courses or engage in noncommercial academic research at levels above the undergraduate level, but the research or courses must be in one of the following disciplines: humanities, social sciences, law, or business.
- Online Courses: Yale departments or schools can offer undergraduate level online courses in humanities, social sciences, or business to individuals who ordinarily live in Iran. Introductory undergraduate courses in science, technology, engineering and math which are ordinarily required for the completion of an undergraduate degree in humanities, social sciences, law or business are also allowed.
2. Other Educational Activities
- Admissions: Yale departments or schools may engage in financial transactions related to recruiting and admitting students from Iran to Yale programs
- Faculty Hiring: Yale departments or schools may engage in financial transactions related to the recruitment, hiring, or employment in a teaching capacity of faculty located in Iran, or who are currently outside Iran but ordinarily live in Iran, and regularly are employed in a teaching capacity at an Iranian university.
- Informational Materials: Yale faculty, students, or staff can export, import or transmit informational materials such as publications, photographs, microfiche, and artworks to or from Iran. The regulations clearly state that this exemption does not include “information and informational materials not fully created and in existence at the date of the transactions, or the substantive or artistic alteration or enhancement of informational materials, or the provision of marketing and business and consulting services.”
- Publishing: Yale faculty, students, and staff can engage in activities that are “necessary and ordinarily incident to the publishing and marketing of manuscripts, books, journals, and newspapers in paper or electronic format…” In short, Yale persons can participate in activities that are part of the normal academic peer-review or publishing process.
- Conferences in Iran: There has been a debate recently as to whether or not U.S. persons can travel to Iran to participate in or speak at academic conferences. Any Yale faculty, staff, or student wishing to travel to Iran to participate in a conference (or any activity listed above) must first contact Don Deyo, Director of Export Control Licensing, at 203-785-3817.
3. Personal Travel
Unlike the embargo of Cuba, the U.S. embargo of Iran does not broadly restrict personal, recreational or tourist travel. In short, Yale faculty, students or staff may engage in personal or recreational travel within Iran subject to Yale policies for student travel listed above.
B. Other Permitted Activities
Activities in addition to those described in A above may be permissible. For example, the regulations allow travel to engage in certain humanitarian activities. In addition, educational activities not listed above may be permitted if you apply for pre-authorization from the U.S. government in the form of a “specific license.” Individuals interested in activities sponsored by or under the auspices of Yale not listed above must contact Don Deyo, Director of Export Control Licensing, at 203-785-3817 for guidance and assistance.
C. Financial Transactions Possible with U.S. Government Authorization
Financial transactions with Iranian entities or Iranian nationals other than those described above may not be permissible or may require a specific license. Furthermore, while US regulations do allow for U.S. banks to process transfers of funds related to Iran, U.S. banks may not directly debit or credit an Iranian bank account. In other words, transfers of money to and from Iran must first be processed through a bank in a third country (e.g. Kuwait). The fact that Iranian accounts cannot be directly debited or credited has and continues to provide significant hurdles to engaging in activities with Iranian nationals. Individuals interested in engaging in any financial transactions with Iran even if they do not involve travel to Iran must first contact Don Deyo, Direct of Export Control Licensing, at 203-785-3817 to discuss the transaction and determine any compliance limits or requirements.