US sanctions and ‘overcompliance’ hit Iranian academia
The latest tightening of United States sanctions on Iran is creating new uncertainty for Iranian students, academics and researchers, while adding another layer of complexity to international academic collaboration.
The measures illustrate how geopolitical conflict is increasingly leading to the weaponisation of the infrastructure of international higher education, raising difficult questions for university leaders about academic exchange, research security and institutional autonomy.
This US policy shift comes at a time when Iranian scholars already face several sanction-related challenges, including limited access to certain scientific resources and specialised information, participation in international academic conferences and the transfer of research materials and equipment along with the payment of publication and registration fees due to banking restrictions.
But some of the difficulties for the Iranian academic community are being caused by overcompliance, with US universities and higher education service providers imposing restrictions beyond those required because they perceive that the compliance risk is too high.
On 24 August the US Department of the Treasury began Operation Economic Outcast (OEO), an unprecedented, whole-of-government, economic campaign against Iran and its enablers to “sever all financial lifelines”.
The department’s Office of Assets Control (OFAC) suspended several general licences that previously authorised certain remittance payments to Iran and Iranian access to the US cultural and academic system.
This included General License G, an authorisation, originally issued in March 2014, which provided a defined legal pathway for certain academic exchanges and educational services involving Iran, including university exchange agreements, scholarships, specified online educational services, some faculty recruitment and the administration of certain professional and university entrance examinations.
Iran’s Minister of Science, Research and Technology, Hossein Simaee Sarraf, said Iranian universities and researchers had faced academic restrictions for years but now “simply taking an exam with Iranian nationality and citizenship is being prohibited”.
For university leaders worldwide, the Iranian case is an example of how geopolitical conflict is increasingly reaching into the everyday mechanisms of international higher education – from admissions and language testing to research partnerships, financial transactions and institutional compliance.
Risks from overcompliance
For universities involved in collaborating with Iranian universities, the challenge of complying with sanctions is not simply determining what is prohibited by law. It also means understanding what activities remain permissible and what require additional review.
In addition, where international academic collaboration depends on a complex infrastructure involving banks, publishers, technology companies, testing organisations, immigration systems, research funders and institutional compliance departments, cautious approaches by a number of the organisations involved can lead to a domino effect, in which the practical restrictions experienced by students and academics become wider than the original legal measures intended.
Exchange programmes halted
The suspension by OFAC halts activities previously authorised under the licence, unless covered by separate legal exemptions.
General License G aimed to maintain educational diplomacy channels. The framework permitted certain undergraduate and graduate exchange programmes, US scholarships for Iranian students and the hiring of Iranian university faculty under US visa regulations.
It also authorised US institutions to process admission fees and offer access to select online courses, non-degree programmes, and MOOCs across humanities, law, business and introductory STEM fields.
Furthermore, the licence enabled non-commercial joint research in Iran, non-profit literacy reform initiatives and the administration of professional certification and university entrance exams.
As part of a broader trend towards research security, on 17 August, the
US Department of War had ordered 30 domestic academic institutions to review their academic, financial and research ties with foreign entities of concern in several countries, including Iran, that engage in activities threatening US national security interests.
The 30 US institutions must audit identified foreign collaborations, assess exposure of sensitive or export-controlled research and take mitigation measures, including terminating problematic partnerships, to remain eligible for future federal research funding.
Nine Iranian institutions appear on the list of the foreign entities of US concern, including Amirkabir University of Technology, Baqiyatallah University of Medical Sciences, Imam Baqir University, Imam Hussein University, Malek Ashtar University, Naval University of Imam Khomeini, Shahid Sattari Air Force University, Sharif University of Technology and Supreme National Defense University.
US universities issue collaboration guidance
The security measures may leave some US university leaders with difficult decisions to make over where to draw the line between legitimate and required security controls and self-imposing unnecessary broad restrictions on scholarly exchange.
In response to the suspension of General License G, American universities issued guidance on working with Iranian collaborators. For example, the University of Colorado said: “educational services, online instruction, academic exchanges, conferences and similar activities involving individuals physically located in Iran may require additional review”.
But the impact of the guidance may reach beyond US universities as OFAC compliance requirements treat US-based international education credential providers and testing companies as intermediaries subject to the Iran sanctions.
Additionally, the Educational Testing Service (ETS) and Duolingo announced they would block Iranians from taking English proficiency exams required for international study, according to a 4 September statement issued by the National Iranian American Council (NIAC), which also indicated that “Pearson PLC and Pearson VUE have abruptly cancelled scheduled Pearson Test of English (PTE) exams and invalidated pre-purchased vouchers for Iranian test-takers outside of Iran, citing compliance with US sanctions”.
Educational Testing Service (ETS), the nonprofit organisation which holds TOEFL and GRE language exams required to get into thousands of universities worldwide, paused administration of the tests in Iran and cancelled previously booked test appointments.
However, Iranian nationals “may take the TOEFL or GRE test at available testing locations outside Iran, subject to applicable registration requirements and appointment availability in the selected location”.
Duolingo, the American educational technology company that offers the Duolingo English Test (DET), decided to go one step further than ETS by suspending DETs to people testing in Iran or using Iranian government-issued identification, according to an article in the official Duolingo English Test Help Center, “The Duolingo English Test is unavailable in Iran and for users with Iranian IDs”. This means that students using an Iranian ID (passport) may also be affected when attempting to take the test from another country.
After OFAC suspended General License G, on 8 September Pearson indicated on their website that “we are unable to schedule or deliver exams for candidates who are residents of Iran unless they can provide proof of primary residency outside of Iran. Exams currently scheduled for impacted candidates will be cancelled; candidates may contact customer service with any questions”.
The pressure comes at a difficult time for Iran’s higher-education system. On 1 September, the Trade Association of Iranian University Professors warned of a strike, suspending academic activity at universities across the country, should new salary decrees not be implemented by the end of September.
The trade group further warned that continued disregard for the economic welfare of academics could accelerate brain drain, lower scientific productivity and inflict irreversible damage on the country’s human cap.
Impact beyond individual careers
For universities, the loss of researchers can have consequences extending well beyond individual careers. Academic networks, doctoral supervision, research teams and institutional knowledge are difficult to rebuild once a critical mass of scholars has left.
Philip Altbach, professor emeritus and distinguished fellow at the Center for International Higher Education, Boston College, United States, told University World News that although the tightening of American sanctions will “create additional problems” for Iranian students and higher education, there has been in fact “very little collaboration in recent years due to existing sanctions”.
According to the Open Doors Report by the Institute of International Education (IIE), the United States hosted approximately 12,656 Iranian students in the 2024 to 2025 academic year. This was a 1.8% increase on the previous year.
Altbach said that cutting off access to English language tests would be “especially problematic” to Iranian students.
English language tests are a key stepping stone for Iranian students seeking to continue their studies abroad, typically in postgraduate programmes.
Currently the US is not an option for those affected by the Trump administration’s suspension of the issuance of new travel visas, including F1 student visas, for Iranian nationals from 1 January 2026.
But the tests also enable Iranian students to apply to study in other countries or to get better jobs in their own country, where economic pressures are mounting and employment is contracting.
Whether the tests have been withdrawn permanently may depend on whether the testing companies can secure another authorisation, seek a specific OFAC licence or alter how they provide their services, according to analysis of the situation provided by Iran International.
Arshin Adib-Moghaddam, a professor in global thought and comparative philosophies at the School of Oriental and African Studies, University of London, argued that the impact of the US sanctions should be understood as part of a much broader confrontation which has involved the bombing of particular academic institutions and targeted assassination of particular scientists.
Atta-ur-Rahman, UNESCO Science Prize laureate and former coordinator general of the Standing Committee on Scientific and Technological Cooperation of the Organisation of Islamic Cooperation, argues that the latest restrictions risk deepening the isolation of Iran's scientific community.
He said: “Using higher education as a political weapon is a deeply flawed strategy that raises serious moral and ethical concerns.”
He argued that these targeted educational sanctions act “effectively criminalise institutional partnerships, halt joint publications and cut off access to international grants, forcing global entities to entirely sever ties out of compliance fear”.
The response to the sanctions has highlighted the challenges presented in many parts of the world affected by geopolitical tension, with universities and service providers becoming risk-averse intermediaries between governments pursuing geopolitical objectives and scholars seeking to maintain international academic relationships.
Jamal Abdi, president of the National Iranian American Council said: “The Trump Administration’s decision to target students in Iran is draconian, but Pearson appears to be going even further than the law requires by punishing Iranians who are not even in Iran.”
“Notably, Pearson already does not operate in Iran, where the suspension of the recent general licence would be expected to have the most impact. Its decision to bar Iranian nationals who are outside of the country does not appear to be required by the sanctions,” the NIAC statement said.
“This appears to be sanctions overcompliance.”
The NIAC has called on the Trump administration to reverse its suspension of longstanding educational sanctions exemptions.