On August 25, 2022, the US Department of the Treasury’s Office of Foreign Assets Control issued General License M-2 under the Iranian Transactions and Sanctions Regulations (ITSR), 31 CFR Part 560, to enable Iranian students, who are not physically present in the US due to the COVID-19 pandemic, to access certain US online educational services and software for an additional year. Under GL M-2, accredited graduate and undergraduate degree-granting academic institutions in the US and their contractors are permitted to provide online educational services and export educational software to eligible Iranian students until September 1, 2023. GL M-2 replaces and supersedes GL M-1, dated August 24, 2021, in its entirety.
OFAC also updated Frequently Asked Question 853 to provide a general overview of the provisions in GL M-2 and other general licenses issued under the ITSR that provide eligible Iranian students with online learning services and software. OFAC also expressed its commitment to mitigating the adverse impacts of the COVID-19 pandemic and urged US persons interested in exporting services to Iranian students that fall outside of the current authorizations to apply for a specific license through its OFAC License Application Page.