What are the potential federal sanctions issues if a student takes classes online from abroad?

If non-US students wish to pursue distance learning at the Tufts while remaining in their home countries, they are allowed to do so in most cases. However, there are a few things for staff and instructors to consider if those students are in countries subject to comprehensive sanctions regulations administered by the US Office of Foreign Assets Control (OFAC). The federal sanctions rules largely prohibit the unauthorized export and import of goods, services, and money to and from persons located in embargoed locations—currently these are Cuba, Iran, Syria, North Korea, and certain regions of Ukraine. Importantly, the term “services” includes educational services, such as distance learning.

OFAC generally authorizes certain types of international distance learning, which vary by country:

• Cuba: All undergraduate courses are authorized. Graduate courses are not authorized.
• Iran: Undergraduate-level humanities, social sciences, law, business, and basic STEM courses are authorized, subject to certain conditions. (Basic STEM courses refer to introductory undergraduate science, technology, engineering, or math courses ordinarily required for the completion of humanities, social sciences, law, or business degree programs.)
• Syria, North Korea, and the Crimea, Donetsk, and Luhansk regions of Ukraine: No courses are authorized.

If a student is in a sanctioned country and wishes to attend a class outside the scope of existing OFAC authorizations, a specific OFAC license must be obtained with the help of OVPR Research Integrity and Compliance. Such licenses may be granted on a case-by-case basis, and the approval process can take several months.

Besides the content of the courses, a student enrolled in a class must not be an individual listed on restricted party lists.

What are the potential export control issues associated with international distance learning?

The export of equipment, software, samples, and other items to students abroad must comply with the applicable export rules. Restrictions are particularly tight about OFAC-sanctioned destinations or parties, to which even basic consumer electronics (thumb drives, tablets, etc.) may not be sent except as authorized by the US government.

Shipments of most off-the-shelf consumer electronics to students in non-sanctioned countries such as Canada, China, and India will not require any sort of export license. However, certain sensitive or sophisticated items (such as encryption software, nanomaterials, satellite components, and UAVs, among other items) could be subject to consequential export controls.

Consult with the OVPR Research Integrity and Compliance if planning to ship tangible items of any sort to an OFAC-sanctioned country, or if planning to send any unusual, sensitive, or cutting-edge equipment or materials to any destination abroad.