Travel to Iran & other sanctioned countries
Important information: All UCM employees planning on travel to Iran or other sanctioned countries for the purposes of University business should contact the Research Compliance & Integrity Office prior to travel.
Recently, the UC Office of the President (UCOP) issued guidance to all campuses advising them to obtain a license from the U.S. Treasury Department, Office of Foreign Asset Control (OFAC) for all employees traveling to Iran to attend or present at conferences or to engage in survey research.
UCOP issued this guidance in response to public statements made by the OFAC Licensing Division that clarified and confirmed OFAC’s position that a license is required for individuals to attend and/or present at conferences or perform research in Iran. Under the U.S. Export Control Regulations, which includes the Sanctions Programs overseen by OFAC, the U.S. government considers conference attendees and presenters to be receiving and/or providing a “service” in the context of the Iranian Transactions and Sanctions Regulations (31 CFR 560).
Although the federal government implemented the Joint Comprehensive Plan of Action (JCPOA) related to the Iran sanctions earlier this year, the primary U.S. sanctions remain in place (only certain specific sanctions were lifted or liberalized). At this time, the JCPOA has not changed the licensing requirement outlined above or the sanctions program as it relates to University activities. Should this change in the future, such changes will be promptly communicated to the UCM research community.
Any UCM employee who plans to travel to Iran or any other sanctioned country for any University business purpose, including research, should contact Deborah Motton, Assistant Vice Chancellor for Research and Director of Research Compliance at firstname.lastname@example.org (209-383-8655) well in advance of their planned travel to seek a determination regarding whether an OFAC license is required to authorize the travel. OFAC licensing for travel to Iran can take up to two years to obtain.
For more information and guidance, please see: http://rci.ucmerced.edu/export-controls/economic-and-trade-sanctions-ofac