Jun

9

OFAC Announces Travel Ban to Iran


Posted by at 3:22 pm on June 9, 2015
Category: Iran SanctionsOFAC

Imam Khomeini by Kaymar Adl [CC-BY-SA-2.0 (http://creativecommons.org/licenses/by-sa/2.0)], via Flickr https://www.flickr.com/photos/kamshots/515002010/ [cropped]Okay, yes, the headline is clickbait, but it’s also not too far from the truth. (Unlike typical clickbait — such as “Four Foods You Eat That Are Poisonous: Number 4 Will Really Surprise You” or “Twelve Really Famous Movie Stars With Really Bad Teeth” — which is largely untrue.) The basis for this (slightly) sensationalized headline is something an official from the Office of Foreign Assets Control (“OFAC”) said yesterday at the meeting here in DC of the Association of University Export Control Officers.

During a Q&A period, an audience member posed three scenarios and asked which ones, if any, would require an OFAC license. Scenario 1: a faculty member goes to Tehran to attend an open conference and presents a paper in collaboration with Iranian professors that is intended to be published. Scenario 2: a faculty member goes to Tehran to attend the same open conference and reads an already published paper and answers no questions from the audience. Scenario 3: a faculty member goes to Tehran to attend the conference and does nothing but listen.

Easy, said the OFAC representative. (And the answer will really surprise you.) “All three require a license. Merely attending the conference is the provision of a service in Iran.”

By that logic, of course, all travel to Iran is banned. If you go to Iran to see your relatives, you’re providing a service in Iran to your relatives. If you go to Iran to write a story on contemporary Iranian youth, you’re providing a service to contemporary youth in Iran. If you go to Iran to ski, you’re providing a service to Iranian ski resorts. If you go as a tourist and give a fellow tourist directions, you’re providing a service in Iran to your fellow tourist.

Okay, I’m being somewhat unfair. Not all travel is banned to Iran. If you are a penniless, uneducated vagrant unable to speak, hear or otherwise communicate, you can go to Iran without a license. Bon voyage.

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4 Comments:


Is that US citizens?

Comment by Michelle on June 9th, 2015 @ 3:35 pm

    Yes, but I think the OFAC official may have been speaking “out of school.”

    Comment by Clif Burns on June 9th, 2015 @ 4:56 pm

On follow up, the official seemed inclined to agree that if the professor simply read aloud a published paper and answered no questions (or maybe answered questions only by quoting from the paper adding such that all information provided was already in existence), that activity would fall within the exception for informational materials.

Comment by TT on June 9th, 2015 @ 8:24 pm

You have never seen me ski.

Eat your heart out, Tommy Moe.

Comment by Matthew J. on June 10th, 2015 @ 6:08 pm