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Security Alert May 17, 2024

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Travel Advisory January 11, 2024

Iran - level 4: do not travel.

Updated to add the Terrorism Risk Indicator and risk of surrogacy tourism.

Do not travel to Iran due to the risk of terrorism, civil unrest, kidnapping and the arbitrary arrest of U.S. citizens . Exercise increased caution due to wrongful detentions .  

Country Summary: U.S. citizens should not travel to Iran for any reason. U.S. citizens visiting or residing in Iran have been kidnapped, arrested, and detained on spurious charges.

Iranian authorities continue to unjustly detain and imprison U.S. nationals, particularly dual national U.S.-Iranian nationals--including students, journalists, business travelers, and academics--on charges including espionage and posing a threat to national security. Iranian authorities routinely delay consular access to detained U.S. nationals and consistently deny consular access to dual U.S.-Iranian nationals.

Violent extremist groups, including U.S. government-designated terrorist organizations, operate in Iran. ISIS and affiliated groups have claimed responsibility for bombings and other attacks in Iran. The threat of terrorist activity persists, as does the risk of death or injury to bystanders.

The U.S. government does not have diplomatic or consular relations with the Islamic Republic of Iran. The U.S. government is unable to provide routine or emergency consular services to U.S. citizens in Iran.

Companies offering surrogacy services in Iran are misrepresenting the security situation in Iran and the risks of the unregulated surrogacy tourism industry. Private companies that arrange such visits and services put U.S. citizens in danger.  

Due to the risks of operating civilian aircraft within or in the vicinity of Iran, the Federal Aviation Administration (FAA) has issued a Notice to Air Missions (NOTAM) and/or a Special Federal Aviation Regulation (SFAR). For more information U.S. citizens should consult the  Federal Aviation Administration’s Prohibitions, Restrictions and Notices .

Read the  country information page  for additional information on travel to Iran.

If you are currently in Iran:   

• Consider the risks involved in possessing dual  U.S. Iranian nationality .
• Review your personal security plan and visit our website for  Travel to High-Risk Areas .
• Draft a will and designate appropriate insurance beneficiaries and/or power of attorney.
• Discuss a plan with loved ones regarding care/custody of children, pets, property, belongings, non-liquid assets (collections, artwork, etc.), funeral wishes, etc.
• Establish your own personal security plan in coordination with your employer or host organization or consider consulting with a professional security organization.
• Leave DNA samples with your medical provider.
• Have a plan for departing Iran that does not rely on U.S. government assistance.
• Enroll in the  Smart Traveler Enrollment Program (STEP)  to receive Alerts and make it easier to locate you in an emergency.
• Follow the Department of State on  Facebook  and  Twitter/X .
• Visit the CDC page for the latest  Travel Health Information  related to your travel.
• Prepare a contingency plan for emergency situations. Review the  Traveler’s Checklist .

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Embassies and Consulates

Embassy of Switzerland – Foreign Interests Section

Pasdaran, Shahid Mousavi St. (Golestan 5 th) Corner of Paydarfard St., No. 55, Pasdaran Avenue Tehran, Iran Telephone: (98) (21) 2254-2178 and (98) (21) 2256-5273 Emergency Telephone: (41) (58) 465-3333 Fax: (98) (21) 2258-0432 Email:   [email protected] Website: www.eda.admin.ch/tehranfi Virtual Embassy Tehran

All consular services require prior appointments which can be made by phone. The Foreign Interests Section can be reached by phone Sunday through Thursday between 7:45 a.m. and 3:00 p.m.

The Foreign Interests Section does not issue U.S. visas or accept visa applications. The Foreign Interests Section provides limited consular services to U.S. citizens in Tehran including:

• Registering U.S. citizens;
• Responding to inquiries concerning the welfare and whereabouts of U.S. citizens in Iran;
• Rendering assistance in times of distress or physical danger;
• Providing U.S. citizens with passport and Social Security card applications and other citizenship forms for processing at the U.S. Embassy in Bern, Switzerland;
• Performing notarial services;
• Taking provisional custody of the personal effects of deceased U.S. citizens; and
• Providing Social Security Administration assistance to retired U.S. citizens residing in Iran.

Destination Description

See the Department of State’s Fact Sheet on Iran for information on U.S.-Iran relations.

Entry, Exit and Visa Requirements

Before traveling to Iran, please consider the current Travel Advisory .

The Travel Advisory for Iran is Level 4, Do Not Travel. The Department of State recommends U.S. citizens do not travel to Iran due to the risk of terrorism, civil unrest, kidnapping and the arbitrary arrest of U.S. citizens. Exercise increased caution due to wrongful detentions. 

Iranian authorities continue to wrongfully detain and imprison U.S. citizens, particularly U.S.-Iranian dual nationals, on charges including espionage and posing a threat to national security. Iranian authorities have also prevented the departure of U.S. citizens from Iran. U.S. citizens of Iranian origin should consider the risk of being targeted by authorities before planning travel to Iran. Iranian authorities routinely deny dual nationals access to the Foreign Interests Section of the Embassy of Switzerland in Tehran because they consider dual nationals to be solely Iranian citizens.

U.S. passports are valid for travel to Iran. However, U.S.-Iranian dual nationals must enter and exit Iran on Iranian passports. As indicated above, the Iranian government does not recognize dual nationality and will treat U.S.-Iranian dual nationals solely as Iranian citizens. Iranian authorities may consider some U.S. citizens – even those without Iranian passports who do not consider themselves to be Iranian – to be Iranian nationals.  

U.S. government employees, including contractors, are strictly prohibited from traveling to Iran without prior authorization from the Department of State.

U.S.-Iranian dual nationals should obtain, in their Iranian passports, the necessary visas for the countries they will transit on their return trip to the United States so that if the U.S. passports are confiscated in Iran, they may depart Iran with their Iranian passports. These individuals can then apply for new U.S. passports in the country they are transiting.  

U.S. citizens residing in Iran on permanent resident visas must obtain an exit permit each time they depart Iran, regardless of the period of stay. All Iranian passport holders are required to pay an exit tax. More specific information on Iranian passport and exit permit requirements may be obtained from the Iranian Interests Section of the Embassy of Pakistan in Washington, D.C.

The Iranian civil code states that women who marry Iranian men acquire Iranian nationality. If the marriage takes place in Iran, the woman’s U.S. passport may be confiscated by Iranian authorities. A woman must have the consent of her husband to leave Iran or, in his absence, consent from another suitable authority. The Foreign Interests Section of the Embassy of Switzerland in Tehran can provide only limited assistance if a U.S. citizen woman married to an Iranian man encounters difficulty in leaving Iran. In addition, if marriage to an Iranian citizen is not officially recognized by the Iranian government, the couple will be committing the crime of adultery if they travel together, the maximum penalty for which is death.

Please contact the Swiss Embassy or appropriate Iranian authorities for special circumstances cases involving divorce and custody rights in Iran.

The U.S. Department of State is unaware of any HIV/AIDS entry restrictions for visitors to Iran. If you intend to reside in Iran, you must submit to a blood test, which may include an HIV test, in order to apply for a residency permit. Permits will be refused if the HIV test is positive.

Find information on dual nationality , prevention of international child abduction , and customs regulations on our websites.

Safety and Security

As noted in the Travel Advisory for Iran, U.S. citizens visiting or residing in Iran face a significant threat of kidnapping or arrest and detention on spurious charges.

U.S. citizens who travel to Iran despite the Travel Advisory should exercise caution throughout the country, but especially in the southeastern region where foreigners have been victims of criminal gangs. U.S. citizens should avoid travel to areas within 100 kilometers of the border with Afghanistan, near the Iraq border, and generally anywhere east of the line from Bam and Bandar Abbas toward the Pakistani border.

Terrorism: In Iran, there is potential for death or injury because of terrorist attacks. Violent extremist groups, including U.S. government-designated terrorist organizations, operate in Iran. ISIS and affiliated groups have claimed responsibility for bombings and other attacks in Iran. The threat of terrorist activity persists, as does the risk of death or injury to bystanders. Additionally, Iran is a designated state-sponsor of terrorism.

For more information, see our Terrorism page.

Crime: Foreigners occasionally become victims of petty street crime, including robberies and bag-snatchings, in Iran. There have been reports of robberies by police impersonators, usually in civilian clothing. Insist on seeing the officer’s identity card and request the presence of a uniformed officer/marked patrol car. Travelers should take the following precautions:

• Do not surrender any documents or cash;
• Make a copy of your U.S. passport (biographical data page and the page with your Iranian visa) and keep it separate from your original passport;
• Do not carry large amounts of hard currency while on the streets;
• Keep important documents such as passports and valuables in hotel safes or other secure locations;
• Take pre-booked taxis, which are safer than those hailed from the street;
• Check with your hotel or tour guide for information on local scams; and
• Do not buy counterfeit or pirated goods, even if they are widely available. Not only are the bootlegs illegal in the United States, purchasing them may also violate local law.

Demonstrations occur sporadically. They may take place in response to political or economic issues, on politically significant holidays, and during international events. Past demonstrations have turned violent.

• As demonstrations can be unpredictable, avoid areas around protests and demonstrations.
• Check local media for updates and traffic advisories.

Iranian security personnel may at times place foreign visitors under surveillance. Hotel rooms, telephones, computers, fax machines, and other electronics may be monitored, and personal possessions in hotel rooms may be searched. The Iranian authorities may also confiscate cell phones, computers, and other devices. U.S. citizens should consider not taking electronic devices to Iran or deleting personal information from them beforehand.

Disaster Preparedness: Iran is prone to earthquakes, many of them severe. To learn more about the seismic regions of Iran, including the most recent earthquakes, please visit the U.S. Geological Survey website .

International Financial Scams: See the Department of State and the FBI pages for information.

Victims of Crime:

Report crimes to the local police by dialing 110 and contact the Embassy of Switzerland’s Foreign Interests Section at (98) (21) 2254-2178. Remember that local authorities are responsible for investigating and prosecuting the crime.

The local equivalent to the “911” emergency line in Iran is: 115 for ambulance service, 125 for fire, and 110 for police. English speakers, however, are generally unavailable.

See our webpage on help for U.S. victims of crime overseas .

The Department of State, through the Embassy of Switzerland’s Foreign Interests Section, can:

• Replace a stolen or lost passport;
• Help you find appropriate medical care;
• Assist you in reporting a crime to the police;
• Contact relatives or friends with your written consent;
• Explain the local criminal justice process in general terms;
• Provide a list of local attorneys;
• Provide our information on victim’s compensation programs in the United States; and 
• Provide an emergency loan for repatriation to the United States.

Domestic Violence: U.S. citizen victims of domestic violence are encouraged to contact the Embassy of Switzerland’s Foreign Interests Section for assistance. U.S. citizens should note that the Foreign Interests Section may be able to provide limited assistance only and that Iranian law does not prohibit domestic violence.

Tourism: The tourism industry is unevenly regulated, and safety inspections for equipment and facilities do not commonly occur. Hazardous areas/activities are not always identified with appropriate signage, and staff may not be trained or certified either by the host government or by recognized authorities in the field. In the event of an injury, appropriate medical treatment is typically available only in/near major cities. First responders are generally unable to access areas outside of major cities and to provide urgent medical treatment. U.S. citizens are encouraged to purchase medical evacuation insurance. See our webpage for more information on insurance providers for overseas coverage .

Local Laws & Special Circumstances

Criminal Penalties: You are subject to local laws. If you violate local laws, even unknowingly, you may be expelled, arrested, or imprisoned. Long prison terms and solitary confinement are common as are punishments including execution, amputation, flogging, blinding, stoning, and fines. Individuals establishing a business or practicing a profession that requires additional permits or licensing should seek information from the competent local authorities, prior to practicing or operating a business.

Examples of local laws that you may be unfamiliar with include:

• Former Muslims who have converted to other religions, as well as persons who encourage Muslims to convert, are subject to arrest and possible execution;
• Drinking, possession of alcoholic beverages, and drugs are illegal. Penalties for possession, use, or trafficking in illegal drugs in Iran are severe and convicted offenders can expect long jail sentences and heavy fines. Iran executes many people each year on drug-related charges. Penalties for the possession, use, or smuggling of alcoholic beverages may include fines, jail time, or flogging;
• Men and women must adhere to the government-sanctioned dress code; this includes covered hair, arms, and legs for women. The government considers the failure to adhere to its dress code and public displays of affection to be crimes;
• Relations between non-Muslim men and Muslim women are illegal, as are adultery and sex outside of marriage, which are punishable by the death penalty;
• Data storage devices (e.g. DVDs, SD cards) depicting sexual relations and magazines showing unveiled women are forbidden;
• Photography near military and other government installations is strictly prohibited and could result in serious criminal charges, including espionage, which carries the death penalty;
• Importation of pork products is banned; and
• Insulting the government or Muslim faith is strictly forbidden, including on social media. Such violations of Iranian law may result in imprisonment.

Carry a copy of your U.S. passport (biodata page and page with Iranian visa) and some other form of identification with you at all times so that, if questioned by local officials, proof of U.S. citizenship is readily available.

If you are arrested while in Iran, request that the police and prison officials notify the Foreign Interests Section at the Embassy of Switzerland in Tehran immediately to ensure that the United States is aware of your circumstances. Under Iranian law, detainees may also request legal representation, although the authorities sometimes fail to allow timely access to attorneys. 

Furthermore, some laws are also prosecutable in the United States, regardless of local law. For examples, see our website on crimes against minors abroad and the Department of Justice website.

Iran-U.S. Claims Tribunal: The Iranian government reportedly has the names of all individuals who filed claims against Iran at the Iran-U.S. Claims Tribunal at The Hague pursuant to the 1981 Algerian Accords. In addition, the Iranian government reportedly has compiled a list of the claimants who were awarded compensation in the Iran Claims Program administered by the Foreign Claims Settlement Commission. The Iranian government has allegedly been targeting award-holders who travel to Iran. Some former claimants have reported being questioned by Iranian authorities upon their entry into Iran as to the status of payment of their respective awards with a view to recouping the award money. The Iranian government has also reportedly threatened to prevent U.S. claimants who visit Iran from departing the country until they repay their award.

Dual Nationality: U.S. citizens who also possess Iranian citizenship are subject to laws that impose special obligations on citizens of Iran, such as military service or taxes. Iranian-citizen males aged 18-34 are required to perform military service, unless exempt. Young men who have turned 17 years of age will not be allowed to leave Iran without completing their military service.

Money: Non-Iranian credit cards and bank cards cannot be used in Iran. You will not be able to access U.S. or foreign bank accounts using ATMs in Iran. You can exchange U.S. dollars for rials, either at banks or with certified money changers. There is no Western Union or similar institution, and bank transfers are not possible. Due to economic sanctions on Iran, U.S. financial institutions have been known to block or freeze accounts accessed via the Internet from Iran.

Communication: Pre-paid overseas calling cards are available at most newsagents. The Internet is widely used in Iran. There are Internet cafes in most hotels; however, usage may be monitored. The Iranian government blocks access to many social media sites.

Sanctions: U.S. government economic sanctions prohibit most economic activity between U.S. citizens and Iran. The U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) has posted to its website frequently asked questions (FAQs) that provide guidance on U.S. sanctions related to Iran. For further information, consult OFAC’s Iran sanctions resource page or contact OFAC’s Compliance Programs Division at 202-622-2490 or obtain information via fax at 202-622-0077.

For information concerning licensing of imports or exports, contact OFAC’s Licensing Division at by phone at 202-622-2480 or fax at 202-622-1657.

Faith-Based Travelers: Freedom of religion, belief, or non-belief is not protected in Iran. See the following webpages for details:

• Faith-Based Travel Information
• International Religious Freedom Report – see country reports
• Human Rights Report – see country reports
• Hajj Fact Sheet for Travelers
• Best Practices for Volunteering Abroad   

LGBTQI+ Travelers: Same-sex relationships in Iran are criminalized and are punishable by death, flogging, or a lesser punishment. LGBTQI+ individuals are often subject to violence and the law does not prohibit discrimination based on sexual orientation, gender identity or expression, or sex characteristics or recognize LGBTQI+ individuals, couples, or families.

See our LGBTQI+ Travel Information page and section 6 of our Human Rights report for further details.

Travelers with Disabilities: The law in Iran prohibits discrimination against persons with physical, sensory, intellectual or mental disabilities, and the law is enforced. Social acceptance of persons with disabilities in public is not as prevalent as in the United States. The most common types of accessibility may include accessible facilities and access to services. Expect accessibility to be limited in public transportation, lodging, communication/information, and general infrastructure.

Students: See our Students Abroad page and FBI travel tips .

Women Travelers: See our travel tips for Women Travelers .

Women in Iran lack certain basic rights such as the freedom to choose their style of dress and restrictions on freedoms of expression and assembly. Gender-based violence is more common in Iran than the U.S., especially in rural areas, and reports of this violence in recent years have steadily increased. “Honor killings” or other harmful practices involving mostly women killed by their male relatives in the name of preserving the family’s “honor” are known to occur. There are also reports of fathers or relatives forcing their female family members to enter a marriage against their will. Domestic violence remains a taboo subject in Iran, and Iranian law does not prohibit domestic violence. Hijab enforcement in Iran is becoming stricter. The Government has deployed Hijab enforcers in public to ensure compliance. Hijab defiance has led to assault, arrest and even death. 

For emergency services in Iran, dial 115.

Ambulance services are

• Widely available but training and availability of emergency responders may be below U.S. standards;
• Not equipped with state-of-the-art medical equipment; and 
• Injured or seriously ill travelers may prefer to take a taxi or private vehicle to the nearest major hospital rather than wait for an ambulance.  

We do not pay medical bills. Be aware that U.S. Medicare does not apply overseas. Most hospitals and doctors overseas do not accept U.S. health insurance.

Medical Insurance: Make sure your health insurance plan provides coverage overseas. Most care providers overseas only accept cash payments. See our webpage for more information on insurance providers for overseas coverage . Visit the U.S. Centers for Disease Control and Prevention for more information on type of insurance you should consider before you travel overseas.

We strongly recommend supplemental insurance to cover medical evacuation.

Always carry your prescription medication in original packaging, along with your doctor’s prescription. Check with the Ministry of Health to ensure the medication is legal in Iran.

Basic medical care and medicine are available in the principal cities but may not be available in rural areas in Iran. Medical facilities do not meet U.S. standards and sometimes lack medicine and supplies.

Vaccinations:  Be up-to-date on all  vaccinations  recommended by the U.S. Centers for Disease Control and Prevention.

Further health information:

• World Health Organization
• U.S. Centers for Disease Control and Prevention (CDC)

Assisted Reproductive Technology and Surrogacy 

• Companies offering surrogacy services, an unregulated industry, are misrepresenting the security situation in Iran. Private companies that arrange such visits and services put U.S. citizens at risk.
• If you are considering traveling to Iran to have a child through use of assisted reproductive technology (ART) or surrogacy, please see our ART and Surrogacy Abroad webpage . Carefully consider the length of time needed to obtain a newborn’s required civil documents to avoid any unintended overstay of your visa.

Air Quality

• Air pollution is a significant problem in several major cities in Iran particularly in Ahvaz, Tehran, and Zabol. Consider the impact seasonal smog and heavy particulate pollution may have on you and consult your doctor before traveling if necessary.
• Infants, children, and teens;
• People over 65 years of age;
• People with lung disease such as asthma and chronic obstructive pulmonary disease (COPD), which includes chronic bronchitis and emphysema;
• People with heart disease or diabetes; and
• People who work or are active outdoors.

Water Scarcity: Iran has a water scarcity issue throughout the country, largely impacting rural communities. Iran is prone to significant droughts in the hot summer months. In cities outside of Tehran, water may be harder to obtain given the availability in those regions and larger water reserves servicing the capital. Tap water in Iran is relatively safe, however it is recommended to consume bottled water, which is regularly available. 

Travel and Transportation

Road Conditions and Safety:   While in Iran, you may encounter road conditions that differ significantly from those in the United States. Travelers in possession of International Driver’s Permits may drive in Iran, though the Foreign Interests Section in Iran does not recommend that tourists do so. Iran has a very high rate of traffic accidents, the second highest cause of mortality in the country. Drivers throughout Iran tend to ignore traffic lights, traffic signs, and lane markers. Urban streets are not well lit; it is therefore particularly dangerous to drive at night. Sidewalks in urban areas exist only on main roads and are usually obstructed by parked cars. In residential areas, few sidewalks exist. Drivers almost never yield to pedestrians at crosswalks. If you are involved in an accident, no matter how minor, do not leave the scene; wait until the police arrive to file a report.

Traffic Laws: Iranian authorities sometimes set up informal roadblocks, both in cities and on highways, often manned by young, inexperienced officers who are suspicious of foreigners. Carry identification with you and avoid getting into disputes.

See our Road Safety page for more information.

Aviation Safety Oversight: As there is no direct commercial air service to the United States by carriers registered in Iran, the U.S. Federal Aviation Administration (FAA) has not assessed the government of Iran’s Civil Aviation Authority for compliance with International Civil Aviation Organization (ICAO) aviation safety standards. Further information may be found on the FAA’s safety assessment page .

Maritime Travel: Mariners planning travel to Iran should check for U.S. maritime advisories and alerts . Information may also be posted to the  U.S. Coast Guard homeport  website, and the  NGA broadcast warnings website.

Port Security: The Commandant of the Coast Guard has determined that effective anti-terrorism measures are not in place in Iranian ports and has imposed conditions of entry on vessels that arrive in U.S. ports having visited ports in Iran. Mariners and passengers traveling through the ports of Iran should exercise increased caution.

For additional travel information

• Enroll in the  Smart Traveler Enrollment Program (STEP)  to receive security messages and make it easier to locate you in an emergency.
• Call us in Washington, D.C. at 1-888-407-4747 (toll-free in the United States and Canada) or 1-202-501-4444 (from all other countries) from 8:00 a.m. to 8:00 p.m., Eastern Standard Time, Monday through Friday (except U.S. federal holidays).
• See the  State Department’s travel website  for the  Worldwide Caution  and  Travel Advisories .
• Follow us on  Twitter  and  Facebook .
• See  traveling safely abroad  for useful travel tips.

Review information about International Parental Child Abduction in Iran . For additional IPCA-related information, please see the International Child Abduction Prevention and Return Act ( ICAPRA ) report.

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Export Controls: Iran Sanctions Guidance Document

It is critical that faculty, staff and students wishing to travel to Iran or engage with an Iranian entity (including a university in Iran), consult with Cornell’s Export Control Office .

The existing U.S. sanctions imposed against Iran are the strictest ones to date. The current Iranian Transactions and Sanctions Regulations (ITSRs) were fully imposed on November 5, 2018 and are administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). It is critical that faculty, staff and students wishing to travel to Iran or engage with an Iranian entity (including a university in Iran), consult with Cornell’s Export Control Office prior to engaging in the activity. 1

Prohibitions

Cornell faculty, staff and students may not engage 2 in any of the following activities which are expressly prohibited under the ITSR:

• All imports of Iranian goods or services into the United States or to a U.S. Person . E.g.: Accepting samples shipped from Iran for testing or analysis; accepting payment from an Iranian entity; attending a class, lecture, workshop or conference in Iran.
• The above bullet includes transaction with a third party where we have reason to believe that the goods, technology or services are ultimately intended for Iran.
• The above bullet includes transactions with a third party where we have reason to believe that the goods, technology or services will be used in the production of or the incorporation into any goods, technology or services to be supplied to Iran
• Any transaction involving goods or services of Iranian origin.
• Any investment in Iran.
• The transmission of controlled information or technology to an Iranian citizen wherever located.

Exempt Transactions

• Personal communications that do not involve the transfer of anything of value.
• Humanitarian donations (food, clothing and medicine).
• Must be publically available and not restricted by export or proprietary designations.
• Information or materials not fully created and in existence at the date of the transaction (i.e. cannot pay in advance for something not yet completed).
• Alterations of the information or materials.
• Consulting services related to the materials.
• Software subject to the Export Administration Regulations .
• Travel related transactions including baggage for personal use, payment of living expenses and facilitation of travel.

Licenses and Authorizations

While the ITSR imposes a number of prohibitions on dealings with Iran, it may still be possible to engage in an otherwise prohibited activity by utilizing either a specific or general license.

Specific Licenses

It may be possible to engage in an otherwise prohibited transaction, if a specific license is obtained from OFAC. Specific license applications are reviewed by OFAC on a case by case basis. To apply for a specific license, please contact Cornell’s Export Control Officer . Please note that a specific license can take six months or more to be reviewed and approved by OFAC, so allow plenty of time when planning your activity.

Authorizations and General Licenses

OFAC has issued authorizations and general licenses in order to authorize some otherwise prohibited activities. The activities described in the authorizations and general licenses are approved without the need to apply for a specific license. 3 Please contact Cornell’s Export Control Office prior to utilizing one of the authorizations below, as some restrictions may apply. 

• Recipients of visas are authorized to carry out those activities for which such visa has been granted. Certain transactions related to the filing and preparation of visa applications are also authorized.
• Personal telecommunications and mail transactions are authorized, as long as nothing of value is transmitted.
• Certain transactions related to intellectual property protection are authorized (e.g., filing for patent protection).
• The collaboration may involve only transactions that are necessary and ordinarily incident to the creation and publication.
• Does not authorize development, production or design of software or any controlled item or technology.
• The exchange of personal communications over the Internet, such as instant messaging, chat and email and social networking is authorized, provided that such services are publicly available and at no cost to the user. 4
• Recruit, hire and employ faculty and staff who are ordinarily resident in Iran.
• Recruit, enroll and educate students who are ordinarily resident in Iran.
• Recruit individuals ordinarily resident in Iran, such as scholars, artists, performers, speakers, alumni, and students, to participate in events, such as conferences, lectures, film series, research workshops, exhibitions, theatrical and musical performances, and continuing education courses. U.S. undergraduate institutions are authorized to provide compensation, including honoraria, to such individuals.
• Authorizes U.S. academic institutions to enter into student exchange agreements with universities located in Iran.
• Those necessary to the filing and processing of applicants and the acceptance of payments for submitted applications and tuition from or on behalf of Iranian citizens.
• Those related to the recruitment and employment in a teaching capacity of Iranian citizens who are already employed in a teaching capacity at an Iranian university, provided the appropriate visa is granted.
• Participation in educational courses or engagement in non-commercial academic research at Iranian universities at the undergraduate level by U.S. persons who are actively enrolled in U.S. academic institutions.
• Participation in educational courses or engagement in non-commercial academic research at Iranian universities at the graduate level in the areas of humanities, social sciences, law or business.
• The participation by Iranian citizens in undergraduate level online courses provided by U.S. academic institutions in the fields of the humanities, social sciences, law or business provided that the courses are of the type ordinarily required for the completion of undergraduate degree programs in the humanities, social sciences, law or business, or are introductory undergraduate level science, technology, engineering, or math courses ordinarily required for the completion of undergraduate degree programs in the humanities, social sciences, law or business.
• Available only to Iranian students (individuals located in Iran, or located outside Iran but who are ordinarily resident in Iran), who are eligible for non-immigrant classification under categories F (students) or M (non-academic students), and have been granted a non-immigrant visa by the U.S. State Department, but are not physically present in the United States due to the COVID-19 pandemic .
• The provision of online educational services related to graduate educational courses, provided that the courses are the equivalent of courses ordinarily required for the completion of graduate degree programs in the humanities, social sciences, law, or business, or are introductory science, technology, engineering, or mathematics courses ordinarily required for the completion of graduate degree programs in the humanities, social sciences, law, or business, and participation in all activities related to the provision of such online educational services to Iranian students. 
• The exportation of software to Iranian students in order to facilitate participation in the activities authorized above or in Iran General License G, provided such software is designated as EAR99 under the Export Administration Regulations, or constitutes information or software not subject to the EAR.
• Authorizes the export (including for travel purposes) to Iran of fee-based or no-cost services incident to the exchange of communications over the Internet such as instant messaging, chat, email, social networking, sharing of photos, video conferencing, web browsing, blogging, e-learning platforms, automated translation, web maps, and user authentication services, as well as cloud-based services in support of the foregoing or of any other transaction authorized or exempt under the ITSR.
• Authorizes the export to Iran of fee-based or no-cost software designated as EAR99 or 5D992.c, that is necessary to enable services incident to the exchange of communications over the Internet such as instant messaging, chat, email, social networking, sharing of photos, web browsing, blogging, social media platforms, collaboration platforms, video conferencing, e-gaming, e-learning platforms, automated translation, web maps, and user authentication services .
• Standard mobile phones, PDAs, SIM cards and most mobile operating systems 6
• Standard laptops, tablets and personal computing devices
• Some anti-virus software
• Standard VPN software
• 1 The lists of prohibitions and authorizations contained in this document are not all-inclusive. In addition, certain restrictions may apply.
• 2 Without confirmation from the Export Control Office that a license or general authorization applies.
• 3 U.S. banks may only process transfers of funds to or from Iran, or for the direct or indirect benefit of persons in Iran, if the transfer arises from, and is ordinarily incident and necessary to give effect to, an underlying transaction that has been authorized by a specific or general license and the payment does not involve debiting or crediting an Iranian account or involve an entity on a government restricted party list.
• 4 Also see General License D-1.
• 5 Contact the Export Control Office for confirmation.
• 6 Taking your laptop or mobile device when you travel significantly increases the possibility of data and identity theft. If you are traveling to high-risk countries or countries with technological restrictions, a free travel loaner system will make travel easy while helping secure your data. Visit https://it.cornell.edu/highrisktravel to learn about Cornell’s loaner device program.

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Iran Sanctions

The diplomatic relationship between the U.S. and Iran is affected by numerous geopolitical factors and is subject to change on short notice. In May 2018, the U.S. withdrew from the Joint Comprehensive Plan of Action (JCPOA), the agreement under which the U.S. had relaxed its sanctions program. While limited commercial activity is permitted with Iran, the majority of the U.S. Office of Foreign Assets Control's (OFAC)  sanction program  remains in effect for Iran. If your research involves collaboration with, or travel or shipping to, an Iranian entity or individual(s), contact  [email protected]  for consultation.

Education Services

Under General License G issued by OFAC, U.S. academic institutions are permitted to provide certain educational services and academic exchanges with Iranian universities and students. Iranian students may apply for non-immigrant visas to attend academic institutions in the U.S. Iranian students may also participate in undergraduate-level online courses provided by U.S. academic institutions in the humanities, social sciences, law or business that are the equivalent to courses ordinarily required for the completion of undergraduate degree programs in the humanities, social sciences, law or business — or in introductory-level science, technology, engineering, or math courses that are ordinarily required for the completion of undergraduate degree programs in the humanities, social sciences, law or business.

U.S. persons who are actively enrolled in a U.S. academic institution are authorized to participate in educational courses and engage in noncommercial academic research at Iranian universities at the undergraduate level. Participation in graduate-level courses and noncommercial academic research in the humanities, social sciences, law or business is also permitted.

This authorization for education services is nuanced with stipulations that are too numerous to list here. If you’re interested in providing or obtaining educational services to or from Iran, contact  [email protected]  for consultation.

Research Activities

Outside of the undergraduate and limited graduate-level research explained above, research collaborations between NC State and Iranian entities remain restricted under OFAC’s sanctions program. While certain research results may be exempt from export controls under the Fundamental Research exclusion, most of the mechanisms and activities involved in sharing this information and collaboration between a U.S.-based entity and an Iranian entity to conduct research are prohibited.  The foundation for this prohibition is that, except for the education services explained above, a U.S. entity — including individuals operating under U.S. jurisdiction — is prohibited from providing services to Iranian entities — including individuals operating under Iranian authority. The nuances of these prohibitions are too many to list here, so if you are seriously considering a research endeavor involving an Iranian entity in any way, contact  [email protected]  for a consultation.

OFAC has a licensing process whereby specific authorizations for a proposed research effort may be requested. This process is lengthy, in some cases taking more than a year, and there is a general policy of denial for these requests. Contact  [email protected]  for more information.

Physical shipments of goods from the U.S. to Iran are prohibited by both OFAC and Bureau of Industry and Security (BIS). Both agencies have mechanisms to apply for licenses to allow the export of items to Iran; however, each agency has a policy of denial for most cases. If a proposed export is in support of an approved activity in Iran (i.e., educational exchange), there is a better chance of obtaining approval.

Information and informational materials are generally permitted for shipment between the U.S. and Iran, provided that these materials do not contain information that is controlled for export under the Export Administration Regulations (EAR) and they are not altered or enhanced after shipment. Examples of informational materials include publications, films, posters, phonograph records, photographs, microfilms, microfiche, tapes, compact disks, CD ROMs, artworks and newswire feeds.

Contact  [email protected]  for instruction on any potential shipments destined to Iran.

Travel to Iran to attend or present at an open conference will require a license from OFAC. Similarly, a presentation via webinar to a live audience that includes individuals inside Iran would also require a license from OFAC. These licenses generally take four to six months to process, but in some instances, they may take a year or more. If you are interested in conducting any of these activities, contact  [email protected]  as early as possible for consultation and assistance.

31 CFR § 560.210 - Exempt transactions.

(a) Personal communications. The prohibitions contained in this part do not apply to any postal, telegraphic, telephonic, or other personal communication that does not involve the transfer of anything of value.

(b) Humanitarian donations. The prohibitions of §§ 560.204 and 560.206 do not apply to donations by United States persons of articles, such as food, clothing, and medicine, intended to be used to relieve human suffering.

(c) Information or informational materials.

(1) The prohibitions contained in this part do not apply to the importation from any country and the exportation to any country of information or informational materials, as defined in § 560.315 , whether commercial or otherwise, regardless of format or medium of transmission.

(2) This section does not exempt from regulation or authorize transactions related to information or informational materials not fully created and in existence at the date of the transactions, or to the substantive or artistic alteration or enhancement of informational materials, or to the provision of marketing and business consulting services. Such prohibited transactions include, but are not limited to, payment of advances for information or informational materials not yet created and completed (with the exception of prepaid subscriptions for widely circulated magazines and other periodical publications); provision of services to market, produce or co-produce, create, or assist in the creation of information or informational materials; and payment of royalties with respect to income received for enhancements or alterations made by U.S. persons to such information or informational materials.

(3) This section does not exempt or authorize transactions incident to the exportation of software subject to the Export Administration Regulations, 15 CFR parts 730 through 774, or to the exportation of goods (including software) or technology for use in the transmission of any data, or to the provision, sale, or leasing of capacity on telecommunications transmission facilities (such as satellite or terrestrial network connectivity) for use in the transmission of any data. The exportation of such items or services and the provision, sale, or leasing of such capacity or facilities to Iran , the Government of Iran , an Iranian financial institution , or any other person whose property and interests in property are blocked pursuant to § 560.211 are prohibited.

See § 560.540 of this part for a general license authorizing the exportation to persons in Iran of certain services and software incident to the exchange of personal communications over the Internet.

(d) Travel. The prohibitions contained in this part do not apply to transactions ordinarily incident to travel to or from any country, including importation or exportation of accompanied baggage for personal use, maintenance within any country including payment of living expenses and acquisition of goods or services for personal use, and arrangement or facilitation of such travel including nonscheduled air, sea, or land voyages.

(e) Official Business. The prohibitions in § 560.211(a) through (c)(1) do not apply to transactions for the conduct of the official business of the Federal Government by employees, grantees, or contractors thereof.

(f) The prohibitions in § 560.211 do not apply to property and interests in property of the Government of Iran that were blocked pursuant to Executive Order 12170 of November 14, 1979, and thereafter made subject to the transfer directives set forth in Executive Order 12281 of January 19, 1981, and implementing regulations thereunder.

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US – OFAC Targets Shadow Banking Network Moving Billions For Iran’s Military.

July 10, 2024 by Rohin Pujari

Overview  

On June 25, 2024, the Department of the Treasury’s Office of Foreign Assets Control (“ OFAC ”)  sanctioned  nearly 50 entities and individuals involved in a shadow banking network used by Iran’s Ministry of Defense and Armed Forces Logistics (“ MODAFL ”) and Islamic Revolutionary Guard Corps (“ IRGC ”). MODAFL is responsible for development, production, funding, and logistics for all of Iran’s defense industries. MODAFL subsidiaries manufacture advanced conventional weapons, including ballistic missiles and unmanned aerial vehicles, which are used by Iran’s military, including the IRGC. This action builds on  previous action  OFAC took in March 2023 against a number of entities that operated as a part of this shadow banking network. We reported on that previous action in the following  post . The Financial Crime Enforcement Network also  issued  an advisory in May 2024 highlighting the ways funds are moved through these shadow banking networks. 

Deputy Secretary of the Treasury Wally Adeyemo made the following comment in light of the action: “The United States is taking action against a vast shadow banking system used by Iran’s military to launder billions of dollars of oil proceeds and other illicit revenue… We have sanctioned hundreds of targets involved in Iran’s illicit oil and petrochemical-related activity since President Biden took office, and we will continue to pursue those who seek to finance Iran’s destabilizing terrorist activities.” 

Iranian Shadow Banking Networks  

Shadow banking networks have been used by MODAFL and the IRGC to gain illicit access to the international financial system and process the equivalent of billions of dollars since 2020. The networks are multi-jurisdictional illicit finance systems which grant sanctioned Iranian entities access to the international financial system and obfuscate their trade with foreign customers. OFAC provided the chart below illustrating how the MODAFL Supply Division uses exchange houses in Iran that manage numerous cover companies registered in permissive jurisdictions such as Hong Kong or the UAE to launder the revenue generated through foreign commercial activity, including oil sales conducted by previously designated MODAFL affiliate Sahara Thunder, into clean foreign currency. 

Networks of Iranian exchange houses and dozens of clandestine shell companies under the network has allowed MODAFL and the IRGC to disguise revenue generated abroad to use for a range of their activities including the procurement of advanced weapons systems such as unmanned aerial vehicles (“UAVs”). Such revenue has also been tied to supporting the provision of weapons to Iran’s regional proxy groups including Yemen’s Houthis, as well as the transfer of UAVs to Russia for use in its invasion of Ukraine. 

OFAC Designations  

Following the illustration above, OFAC issued sanctions targeting entities at several levels of such clandestine networks. OFAC sanctioned the following individuals and entities: 

• OFAC designated Seyyed Mohammad Mosanna’i Najibi (“Najibi”) and Seyyed Mohammad Mosanna’i Najibi & Co. Company (“Sadaf Exchange”). Najibi is an Iranian-Turkish moneychanger who, since at least 2019, has managed several currency exchange businesses in Iran and Türkiye in coordination with the MODAFL Supply Division for the purpose of bypassing US and EU sanctions on Iran. Using Sadaf Exchange, Najibi has enabled the MODAFL Supply Division to conduct dollar-denominated transfers worth hundreds of millions of dollars to other MODAFL cover companies and exchange houses, including to Sahara Thunder and US designated Ansar Exchange. Najibi, Sadaf Exchange, and another involved entity Najibi owns, Golden Stars Kiymetli Madenler Tekstil Sanayi Ticaret Limited Sirketi, were all designated pursuant to E.O. 13224 
• OFAC designated Omid Sepah Exchange Company (“Omid Sepah”) and Hekmat Iranian Exchange & Foreign Currency Services Company (“Hekmat Iranian”). Omid Sepah and Hekmat Iranian are Tehran-based currency exchange businesses controlled by US designated Bank Sepah that use foreign cover companies to engage in shadow banking transactions on behalf of the MODAFL Supply Division, in collaboration with Najibi and Sadaf Exchange.  
• OFAC also designated 27 cover companies based in Hong Kong, the UAE, and the Marshall Islands that are controlled by Najibi. These companies have collectively moved hundreds of millions for dollars’ worth of revenue for MODAFL related to oil and petrochemical sales or foreign currency exchange operations. The cover companies are all being designated pursuant to E.O. 13224, for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, MODAFL. 
• OFAC re-designated Iranian moneychanger Asadollah Seifi (“Seifi”) for his continued involvement in sanctions evasion schemes, following his March 26, 2019 designation pursuant to E.O. 13224 for providing material support to a vast currency exchange network which supported both the IRGC and MODAFL. Seifi conducts sanctions evasion activities in support of the MODAFL Supply Division in Emirati dirham through UAE based shell companies. Seifi also establishes shell companies and accounts for MODAFL’s use, converts or transports foreign currency using couriers, retrieves revenue from oil and petrochemical sales through cover companies, and transfers foreign currency to suppliers of the IRGC.  
• OFAC also designated five shell companies based in the UAE that were controlled and used by Seifi to obfuscate MODAFL’s financial activity under E.O. 13224. 
• OFAC designated Ramin Jalalian (“Jalalian”) is an Iranian currency exchanger and businessman who has managed several currency exchange businesses in Iran and the UAE in coordination with the MODAFL Supply Division for the purpose of bypassing US and EU sanctions on Iran.  
• Two shell companies based in the UAE, and one based in Hong Kong, controlled by Jalalian and used to obfuscate MODAFL’s financial activity, were also designated. Ramin Jalalian and the two shell entities are all being designated pursuant to E.O. 13224. 
• OFAC designated Siavash Nourian (“Siavash”) the owner of Iranian exchange house Siavash Nourian & Co. Exchange (“Nourian Exchange”), which is used by the MODAFL Supply Division for a wide range for foreign currency activities, including establishing cover companies and accounts, holding MODAFL’s money in cover accounts outside of Iran, converting foreign currency, transporting foreign currency using couriers, retrieving revenue from MODAFL’s oil and petrochemical sales, and transferring currency to suppliers of MODAFL and the IRGC.  
• Three shell companies based in Hong Kong and controlled by Nourian Exchange for the purpose of conducting foreign currency transfers on behalf of MODAFL were also designated. Siavash Nourian, Nourian Exchange, and the three shell entities are all being designated pursuant to E.O. 13224. 
• OFAC designated Seyyed Reza Mir Mohammad Ali (“Mir Mohammad Ali”) a key confidant of the MODAFL Supply Division and the CEO and owner of Iran-based Atropars Company (“Atropars Exchange”), another exchange house that the MODAFL Supply Division uses to conduct financial activity outside of Iran. Mir Mohammad Ali establishes cover companies and financial accounts for the MODAFL Supply Division’s use, holds MODAFL funds in cover accounts outside of Iran, conducts foreign currency exchange, transports foreign currency to and from Iran using cover companies and couriers, and transfers foreign currency to suppliers of the IRGC and MODAFL. Between March 2022 and March 2023, Atropars Exchange processed the equivalent of over $40 million in euros in incoming and outcoming transfers. Seyyed Reza Mir Mohammad Ali and Atropars Exchange are being designated pursuant to E.O. 13224. 

For a full list of all the individuals and entities designated in this action please refer to this  link . 

OFAC Designation Implications  

As a result of OFAC’s designations, all property and interests in property of the persons above that are in the United States or in the possession or control of US persons are blocked and must be reported to OFAC. In addition, any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked. All transactions by US persons or within (or transiting) the United States that involve any property or interests in property of designated or blocked persons are prohibited unless authorized by a general or specific license issued by OFAC or exempt. These prohibitions include the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any blocked person and the receipt of any contribution or provision of funds, goods, or services from any such person. 

For further information, please contact:

Jonathan Cross , Partner, Herbert Smith Freehills

[email protected]

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Tehran police close Turkish Airlines office after its employees defy Iran’s headscarf law

Women line up to vote for the presidential election in a polling station at the shrine of Saint Saleh in northern Tehran, Iran, Friday, July 5, 2024. Iran held a runoff presidential election on Friday that pitted a hard-line former nuclear negotiator against a reformist lawmaker. (AP Photo/Vahid Salemi)

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TEHRAN, Iran (AP) — Police in Iran shut down the Turkish Airlines office in the capital of Tehran, Iranian media reported Tuesday, after female employees there apparently refused to wear the mandatory headscarf, or hijab , in an act of defiance of the country’s law.

The semi-official Tasnim news agency said police officers went to the Turkish Airlines office in Tehran on Monday to issue what is called a first warning over the “non-observance of hijab” by the company’s employees.

However, the employees — who are Iranian nationals — reportedly “made trouble for the police officers,” prompting the closure. The Tasnim report said police subsequently sealed the office over the employees’ behavior.

According to Tasnim, the Turkish Airlines office will be allowed to reopen on Wednesday and resume business as usual, something that the police did not confirm. The report further said that police would not seal any business due to the non-observance of hijab but issue first warnings.

There was no immediate comment from the Turkish Airlines over the incident in Tehran.

An open defiance of the headscarf law erupted into mass protests across Iran following the September 2022 death of 22-year-old Mahsa Amini after her arrest by the country’s morality police. While those demonstrations appear largely to have cooled, the choice by some Iranian women to remain uncovered in the street poses a new challenge to the country’s theocracy.

Iranian authorities have over the past years shuttered hundreds of businesses across the country — from shops, restaurants to pharmacies and offices — for quietly allowing their female employees to forgo wearing the hijab.

That reinforcement was intensified in the months running up to Iran’s presidential election in June to replace the late President Ebrahim Raisi who died in a helicopter crash a month earlier.

The fracas at the Tehran office of the Turkish Airlines took place on the same day as Turkish President Recep Tayyip Erdogan called Iran’s President-elect Masoud Pezeshkian to congratulate him on his win in Iran’s presidential runoff last week.

Pezeshkian bested hard-liner Saeed Jalili in the election by promising to reach out to the West and ease enforcement on the country’s mandatory headscarf law after years of sanctions and protests squeezing the Islamic Republic.

The state-run IRNA news agency quoted Tehran Prosecutor Ali Salehi as saying that no legal proceedings or ruling had been issued regarding the sealing the Turkish Airlines office in Tehran.

Iran and Turkey have maintained good relations and in 2023, the volume of bilateral trade between the two stood at $5.4 billion. Turkey is also a popular tourist destination for Iranians, with some 2.5 million visiting last year.

Turkish Airlines is a favored carrier among Iranians because of the shorter travel time to the United States and Canada, compared to other long-haul flights from Arab countries in the Persian Gulf.

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Iran-related Designation; Non-Proliferation Designation

Specially designated nationals list update, the following entity has been added to ofac's sdn list:.

HAKIMAN SHARGH RESEARCH COMPANY, No. 0, Crystal Building, Ground Floor, Khomeini Shahr Ring Street, Azadegan Blvd., Central Sector, Khomeini Shahr City, Isfahan Province 8415683111, Iran; Additional Sanctions Information - Subject to Secondary Sanctions; Organization Established Date 11 May 1999; National ID No. 10260357995 (Iran); Registration Number 2649 (Iran) [NPWMD] [IFSR].

Unrelated Administrative List Updates: