Research and Innovation at The University of Toledo

Before initiating or continuing an activity involving Iran, an Iranian university or organization, or an individual located or ordinarily resident in Iran, members of the  community should contact Export Control for an activity-specific review.

Examples include:

• Research or academic collaborations
• Online instruction or educational services
• Student or scholar exchanges
• Conferences, workshops, and seminars
• Consulting or professional services
• Scholarships, tuition payments, stipends, or reimbursements
• Travel to Iran for University-related purposes
• Transfers of funds, equipment, software, research data, technology, samples, or technical information

Do not enter into an agreement, make a payment, provide services, transfer University resources, or make a commitment to an outside party until the proposed activity has been reviewed.

The restrictions are based on the location of the parties, the nature of the activity, the organizations involved, and other transaction-specific factors. They do not impose a blanket restriction based solely on Iranian citizenship, national origin, or immigration status.

For questions or to request a review, contact:

UToledo Export Control
Research and Innovation
Email: ExportCompliance@UToledo.edu

Additional information is available through the following federal resources:

• OFAC Notice of Suspension of Certain Iranian Transactions and Sanctions Regulations General Licenses
• OFAC Iran-related designations and updates to general licenses

This notice provides general compliance information and does not replace an individualized export control or legal review.

This general license authorizes certain transactions necessary and ordinarily incident to publishing and marketing manuscripts, books, journals, and newspapers in print or electronic formats.

Subject to applicable restrictions, authorized activities may include:

• Commissioning and making advance payments for identifiable written publications.
• Collaborating on or enhancing written publications.
• Adding photographs, artwork, translations, or explanatory text.
• Providing substantive editing.
• Paying royalties.
• Marketing and promoting written publications.

The authorization does not apply when a party is the Government of Iran or is acting on its behalf. However, qualifying academic and research institutions and their personnel are not treated as the Government of Iran for purposes of this provision. Additional restrictions apply.

Important: This authorization generally covers publishing activities, not the underlying research that leads to publication. Research, experiments, fieldwork, data collection, training, or technical services involving Iran may require a specific OFAC license and must be reviewed by UToledo Export Control.

Iran General License D-2 generally authorizes certain services, software, and hardware used for internet-based communications. This may include email, messaging, social media, video conferencing, collaboration platforms, e-learning platforms, cloud-based services, and qualifying security or anti-censorship tools.

The authorization may also cover:

• Laptops, tablets, and smartphones.
• Consumer data-storage devices.
• Computer peripherals and accessories.
• Routers, modems, and communications equipment.
• Anti-virus, anti-malware, VPN, and related software.

Eligibility depends on the item’s export classification, technical capabilities, end user, and intended use. Encryption or other specialized features may affect whether an item qualifies.

Travel reminder: Taking a laptop, phone, software, research data, equipment, or another item to Iran is considered an export, even if it will be brought back to the United States. University-owned items and research materials must be reviewed in advance.