Iran Ban

From an email circulated today:

While the COVID-19 pandemic has temporarily halted our usual University-business travel (e.g., meetings, conferences, fieldwork sites, etc.), I write to you now with an eye towards a future that allows these activities to resume.

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) administers and enforces a comprehensive trade embargo against Iran as set forth in the Iranian Transactions and Sanctions Regulations (ITSR).  These regulations apply to all U.S. citizens, U.S. permanent residents, and U.S.-Iranian dual citizens.  The ITSR generally prohibit almost all direct or indirect commercial, financial, or trade transactions with Iran unless OFAC pre-authorizes the activity through a license.  Therefore, virtually all travel to or engagement in activities with Iran for UCLA business are prohibited without a license from OFAC.

These prohibitions apply regardless of whether the performance of the activity uses UCLA funds or resources.  The impacted UCLA activities include, but are not limited to:

• Attending a conference or award ceremony
• Presenting at an academic conference
• Providing technical assistance or analysis
• Sharing unpublished data/research results
• Teaching
• Conducting research in Iran
• Collaborating with an Iranian institution or individual
• Exporting or importing goods or equipment
• Transferring funds to or from an Iranian institution or individual
• Paid or pro bono patient consultation and care

OFAC has the discretion to impose civil and/or criminal penalties on the institution and the individual.  Each violation of the ITSR may be subject to a civil penalty of up to the greater of $307,922 (as of the writing of this message) or twice the value of each underlying transaction; criminal conviction may result in $1 million in fines and/or imprisonment.

The Office of Research Policy & Compliance serves as the campus point of contact for all Export Control questions and license applications.  While UCLA has been successful in obtaining OFAC licenses in the past, the process can take, at minimum, six months.

Please contact the Export Control team at export.controls@research.ucla.edu to discuss the details of any anticipated travel to or engagements with Iran.  We would be very happy to work with you.

Sincerely,

Ann Pham

Export Control Officer

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COMMENT: One hopes there is some pushback from academia including UC/UCLA to these types of regulations. While there may be some kinds of research that have national security implications, maintaining academic contacts is generally a Good Thing.