On August 24, 2021 the US Department of the Treasury’s Office of Foreign Assets Control issued an Iran-related General License M-1, “Authorizing the Exportation of Certain Graduate Level educational services and Software” pursuant to Iranian Transactions and Sanctions Regulations (ITSR), 31 CFR Part 560. OFAC also updated Frequently Asked Question 853 to clarify these provisions.
GL M-1 temporarily authorizes accredited graduate and undergraduate academic institutions in the US and their contractors to provide certain online educational courses, including certain introductory courses in the areas of science and math and courses required for the completion of graduate degree programs in the humanities, social sciences, law or business to certain eligible Iranian students who are not physically present in the US due to the COVID-19 pandemic. GL M-1 also allows for supporting software to be exported to Iranian students enrolled in such academic programs, if certain conditions are met. These services are authorized until September 1, 2022. GL M-1 is effective immediately, and replaces and supersedes GL M dated October 29, 2020. FAQ 853 provides a general overview of the conditions under which online learning services and software can be provided to Iranian students.