To: Administrators, Deans, Directors, Department Chairs, Executive Officers and Faculty
I am writing to follow up on an email about the Iranian Transactions and Sanctions Regulations (ITSR) sent to campus deans by the UCLA Export Control Officer in August 2020. I know that the email raised a number of unanticipated concerns as many of you were unaware of reminders distributed in past years. The email was sent after UCLA learned of a potential campus violation of the ITSR. Because violations of the ITSR are serious, my goal in providing this update is to make certain that the UCLA community is aware of these regulations and of the resources available to help you navigate them.
Like other trade and economic sanction programs, the ITSR imposes certain limitations on transactions and activities that U.S. persons and entities — like UCLA — can undertake. Other comprehensive sanctions imposed by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) include Cuba, North Korea, Syria and the Crimea Region of Ukraine. As we engage in foreign travel for research, meetings, conferences or ceremonies; or through the transfer of funds, we must be mindful of these laws and regulations.
The ITSR program generally prohibits almost all direct or indirect commercial, financial, or trade transactions with Iran unless OFAC pre-authorizes the activity through a specific license. The ITSR program impacts activities such as attending or presenting at conferences and ceremonies in Iran, and teaching and conducting research in Iran or in partnership with an entity in Iran. It also impacts the physical or digital sharing of goods, equipment, funds, unpublished data/research results, or technical assistance and analysis with Iran. The ITSR program applies to all U.S. citizens, U.S. permanent residents, and U.S.-Iranian dual citizens. In the past, UCLA has been successful at obtaining OFAC licenses that have allowed faculty to undertake otherwise prohibited activities. The process can be lengthy, however, and approval is not guaranteed.
Additionally, the COVID-19 pandemic has given rise to questions about access to remote learning opportunities for students from sanctioned countries who cannot return to the U.S. Similarly, there are questions about whether University of California researchers who cannot return to the U.S. may conduct research or engage in telework. Preliminary information provided by the UC Office of Ethics, Compliance, and Audit Services (ECAS) indicates that these situations will likely require OFAC licenses. Please see the Compliance Alerts recently issued by ECAS.
The UCLA Export Control team within Research Policy & Compliance (RPC) serves as the campus point of contact for all matters related to export control regulations and license applications. Members of the team are available to discuss any questions or concerns you have about the ITSR sanctions and how they may impact your teaching and research. They can also respond to questions about other export control issues.
Please do not hesitate to seek guidance on any export control matter at firstname.lastname@example.org. By working together, we can maximize our ability to continue scholarly work and creative activities within constraints imposed by federal law.
Vice Chancellor for Research and Creative Activities