Purpose
This guidance addresses communications between university faculty and individuals who are located in Iran or who are outside Iran but ordinarily reside in Iran. It applies whether the individual contacts the faculty member directly or through a department or college contact form.
Federal sanctions regulations may restrict the services faculty can provide to individuals in Iran, including activities that normally constitute academic advising. Exports of services to individuals located in or ordinarily resident in Iran are prohibited by the Iran Transactions and Sanctions Regulations unless the federal government provides a specific (usually limited) authorization.
Similarly, University of Nebraska policy prohibits activities that involve individuals located in countries of concern (including Iran) unless specifically authorized by the University President. Executive Memorandum No. 36 prohibits outside professional activities that involve countries of concern, while Executive Memorandum No. 46 prohibits activities involving countries of concern that would otherwise fall within the scope of university employment. Both policies require disclosure of any activities involving countries of concern through the university’s conflict-of-interest process.
In light of this situation, faculty should not assume that activities involving students located in or ordinarily resident in Iran are permitted. These activities must be assessed on a case-by-case basis. The purpose of these FAQs is to provide guidance on when a particular activity is prohibited by federal law or University of Nebraska policy.
Note: Iranian citizenship alone does not determine whether these restrictions apply. An individual's location and ordinary residence, the nature of the proposed activity, and other regulatory restrictions must be considered.
General rule: Sharing public information and maintaining ordinary communications are different from providing individualized academic or research services. When a request goes beyond public information, seek guidance from your campus’s export control office before proceeding.
Contacts for Campus Export Control Offices
These offices are available to answer questions and assist with requests for authorization to engage in prohibited activities.
Frequently Asked Questions
What does it mean to be “ordinarily resident in Iran?”
Because the term “ordinarily resident in Iran” is not defined by federal law and a more detailed, fact-specific analysis is required, if any of the following criteria are present, a closer review will be needed to determine whether an individual is ordinarily resident in Iran. The following factors are important:
- Iranian citizenship
- Citizenship or permanent residence in other countries
- The location of permanent address
If the person can provide evidence to establish that they are ordinarily resident in a country other than Iran, they may not be affected by these prohibitions.
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Examples of people ordinarily resident in Iran:
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Examples of people not ordinarily resident in Iran:
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- Anyone whose permanent address is in Iran (including U.S. citizens)
- Iranian citizens who are temporarily living outside Iran in a country other than the United States for work or study
- Iranian citizens who are also citizens or permanent residents of any other country and whose permanent address is in Iran
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- Iranian citizens who are also citizens or permanent residents of the United States and whose permanent address is in the United States
- Iranian citizens who are temporarily living in the United States for work or study
- Iranian citizens who are also citizens or permanent residents of any other country and whose permanent address is not in Iran
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Can I respond to an unsolicited email from a student in Iran?
You may acknowledge receipt of the message. However, providing substantive academic advice or agreeing to an ongoing advising relationship may constitute an export of services to Iran that is prohibited by both federal law and University of Nebraska policy.
The fact that the individual initiated contact does not, by itself, authorize the provision of academic services.
Can I provide information about my research expertise?
You may direct the individual to publicly available information, such as:
- Your university faculty profile and professional biography
- Publicly available publications and research abstracts
- Public lectures, presentations, and other published materials
- Public descriptions of your research interests and academic department
Note that providing public information is different from providing individualized research assistance. Providing a more substantive response, such as interpreting research findings, recommending a research approach, or helping develop an experiment, is prohibited by federal law and University of Nebraska policy without specific authorization.
Can I answer general questions about a field of study?
Yes, if responses are strictly limited to information that is publicly available. Communication that involves more individualized responses, like instructions, analysis, or professional guidance, is prohibited by federal law and University of Nebraska policy unless specifically authorized.
Not every academic exchange is automatically prohibited, but faculty should not assume that an educational or research-related service is authorized merely because it consists of an email or informal conversation.
A request for publicly available information is different from a request for individualized instruction, analysis, or professional guidance. When the distinction is unclear, refer the request to your campus’s export control office.
Can I advise a student on coursework?
No, unless a specific authorization is in place. Providing assistance with coursework to an individual who is located in or ordinarily resident in Iran is prohibited by federal law and University of Nebraska policy unless specifically authorized.
Examples of prohibited advice include:
- Explaining how to approach a specific assignment
- Reviewing or correcting coursework
- Providing individualized instruction or tutoring
- Helping the student solve particular problems
- Developing a study plan tailored to the student's educational needs
General public resources about a subject may be treated differently from direct educational assistance. See Q4.
Can I help a student develop a thesis or dissertation?
No, unless a specific authorization is in place. If the student is located in or ordinarily resident in Iran, providing assistance in developing a thesis or dissertation is prohibited by federal law and University of Nebraska policy unless specifically authorized.
Do not agree to supervise, advise, or provide substantive feedback on a thesis or dissertation for an individual in Iran without prior review by your campus’s export control office.
Examples that require review include:
- Helping formulate or refine a research question
- Recommending a methodology tailored to the student's project
- Reviewing a proposal, draft chapter, or dissertation
- Providing feedback on the student's analysis or interpretation of results
- Meeting regularly to discuss research progress
- Helping plan experiments, data collection, or other research activities
These activities may constitute prohibited academic or research services.
Can I discuss my published research with a student in Iran?
Yes. Sharing links to publicly available publications is generally different from providing individualized research services. The transmission to Iran of publicly available information is explicitly authorized by 31 C.F.R. § 560.210(c).
However, federal law and University of Nebraska policy prohibit providing tailored analysis, interpretation, technical instruction, or assistance applying research methods to the student's own project unless specifically authorized. See Q4, Q5, Q6.
Also consider whether the proposed exchange involves unpublished research, proprietary information, controlled technology, or other information subject to separate export control restrictions.
Can I meet with the student by email, video conference, or another online platform?
Yes. The use of email, video conferencing, and other internet communications is generally authorized by 31 CFR § 560.540, subject to an important caveat explained below. Personal communications are also generally authorized by 31 C.F.R. § 560.210(a). This means you do not need to obtain specific authorization to use these technologies for authorized communication.
However, authorization to use a communications platform does not automatically authorize the substantive academic services provided through it. It is necessary to assess both the communications technology and the content and purpose of the interaction. See Q4, Q5, Q6.
For questions about the use of communications technologies when interacting with an individual located in or ordinarily resident in Iran, contact your campus’s export control office.
Can I collaborate with the student on research?
No, unless a specific authorization is in place. If the student is located in or ordinarily resident in Iran, collaborative research is prohibited by federal law and University of Nebraska policy unless specifically authorized.
Do not initiate a research collaboration with an individual in Iran without first consulting your campus’s export control office, particularly if the collaboration would involve any of the following:
- Sharing unpublished research or nonpublic technical information
- Providing research data, software, equipment, or technical instructions
- Jointly developing methods, designs, code, or other research outputs
- Conducting experiments or analyzing data together
- Providing access to university research facilities or systems
- Funding, compensation, or other financial arrangements
These activities are all generally prohibited by federal law and University of Nebraska policy unless specifically authorized by the Treasury Department. Your campus’s export control office can advise on the process for obtaining authorization.
What should I do if I am unsure whether a response is permitted?
Pause before providing substantive assistance and contact your campus’s export control office. Include the individual's location and institutional affiliation, the request they made, the assistance you are considering, and any relevant information or technology you would share.
Do not assume that an activity is permissible solely because it is informal, unpaid, initiated by the student, or conducted through a third-party platform.
