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In these unprecedented times, many FIU academic units are working to support remote education and distance learning for students around the world. It is the mission of the export office to support these efforts to the fullest extent possible.
Providing course instruction to international students: most institutional courses provided in either a traditional or online format are not subject to export control under the public information and/or educational information exclusions. However, providing services to individuals located in a foreign country may constitute a provision of services which is regulated under export controls. This is particularly critical when providing graduate level instruction.
Faculty and staff who wish to provide distance education courses to international participants should contact Export Control for assistance in determining whether the course requires any specific enrollment screening and/or controls. Where controls are required, Export Control will work with the faculty member, the Office of Distance Education, and IT to ensure that appropriate controls are implemented.
Providing Distance Education to Students located in Iran: The OFAC General License G (see text below) outlines certain circumstances when U.S. academic institutions are authorized to provide distance education to students located in Iran. When educational activities fall under Gen. License G, no Specific License is required from OFAC. However, this provision is strictly limited to undergraduate course work and pursuant to the specific conditions stated therein. Graduate level on-line course offering is NOT permitted without a Specific License.
Note that there has been some confusion about undergraduates taking graduate-level courses: such situations have been interpreted as falling outside Gen. License G and would therefore require a specific license.
When a specific license to offer either a) graduate level courses; and/or b) undergraduate level courses that fall outside of the subsection (iii) allowance below, FIU faculty and staff should assume that it will take a minimum of 60 to 90 days (at best) to procure such licenses for each individual located in Iran.
If you anticipate providing distance education to international students who may be located in Iran, contact the Export Office as soon as possible to assess whether export licenses may be required.
OFFICE OF FOREIGN ASSETS CONTROL Iranian Transactions and Sanctions Regulations 31 C.F.R. Part 560 GENERAL LICENSE G Certain Academic Exchanges and the Exportation or Importation of Certain Educational Services Authorized
(b) Educational Services. Except as provided in paragraph (c) of this general license,
(1) U.S. academic institutions, including their contractors, are authorized to export services:
(iii) to individuals located in Iran, or located outside Iran but who are ordinarily resident in Iran, to sign up for and to participate in undergraduate level online courses (including Massive Open Online Courses, coursework not part of a degree seeking program, and fee-based courses) provided by U.S. academic institutions in the humanities, social sciences, law, or business provided that the courses are the equivalent of courses ordinarily required for the completion of undergraduate degree programs in the humanities, social sciences, law, or business, or are introductory undergraduate level science, technology, engineering, or math courses ordinarily required for the completion of undergraduate degree programs in the humanities, social sciences, law, or business.
Shipping course materials or software to an international student: most basic course materials such as textbooks, standard computing devices, laboratory supplies, office supplies, and textiles do not require an export license. However, shipments of certain items, or shipments to specific destinations, may require either an export license and/or a special customs filing. Shipments that do not have appropriate export and customs documentation risk being delayed and/or destroyed by Customs, and may result in costly fines. Please review our extensive Shipping information for instructions on how to ship items abroad.
If you are shipping items to Iran, Syria, Cuba, North Korea, China, Russia, and/or Venezuela, please contact the Export Office immediately, as shipments to these destinations require either an export license, additional export control review, and/or special customs filing.