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Online Coursework in Sanctioned Countries
Some U.S export control regulations prohibit offering and taking online (internet-based) courses abroad without an appropriate license.
Federal export licenses are required to provide educational services, such as distance learning or online instruction, to students located in the comprehensively embargoed and sanctioned countries. There may also be license requirements for the e-learning or web conferencing software used to deliver the courses virtually.
Contact the U-M Export Controls Office when planning to conduct courses or webinars to students/audiences located outside the United States to determine the licensing requirements. Note: it may take 6 months or longer to obtain federal export licenses.
Country-specific licensing requirements for online courses
Country |
Course Level/Description |
License Requirement |
|---|---|---|
| Cuba | Undergraduate or below | Allowable under General license |
| Graduate | Unallowable without OFAC license | |
| Online course software | EAR licensing determination required | |
| Iran |
|
Allowable under General license |
|
Introductory undergraduate level courses in science, technology, engineering, or math, intended or required for the completion of undergraduate degree programs in the humanities, social sciences, law, or business. Not allowed for degree programs in science or engineering. |
Allowable under General license | |
| Introductory undergraduate level courses required for the completion of degree programs in engineering, science, or math | Unallowable without OFAC license | |
| Graduate level | Unallowable without OFAC license | |
| Online course software | EAR licensing determination required | |
| North Korea | All levels | Unallowable without OFAC license |
| Syria | Undergraduate and graduate level | Unallowable without OFAC license |
| Crimean, Donetsk, & Luhansk Regions of Ukraine | Undergraduate and graduate level | Unallowable without OFAC license |
| Foreign Students within U.S. | Those on non-immigrant visas may “carry out in the United States those activities for which such a visa has been granted.” (31 CFR § 560.505) | |
AUECO chart adapted by the University of Michigan Export Controls Program
Questions?
Questions? Email the Export Control Office at: exportcontrols@umich.edu