Iran General License G Is Suspended, and OFAC Now Presumes Denial: What Schools Should Do Now

On August 24, 2026, the Treasury Department’s Office of Foreign Assets Control (OFAC) indefinitely suspended five authorizations under the Iranian Transactions and Sanctions Regulations (ITSR). One of them, Iran General License G, is the authorization U.S. colleges, universities, and schools have used since 2014 to process applications and accept tuition from students in Iran, offer them certain online courses, and run academic exchanges with Iranian universities. The same license covered administering university entrance exams to people in Iran.

OFAC’s August 24 notice pointed anyone who wanted to continue that activity to its specific-license process. On September 10, OFAC told applicants what to expect. Its new Statement of Licensing Policy establishes a presumed denial for Iran-related license requests and says specific licenses may only be issued “as required by law or in exceptional and urgent circumstances, such as risk to life, limb, or environmental safety.”

For a business office, an admissions team, or an international student office, that second document changes the plan. Here is what was suspended, what General License G actually covered, what was left in place, and what a school’s process needs now.

The suspensions took effect August 24, 2026, and were published in the Federal Register two days later (91 FR 54957). They were part of Operation Economic Outcast, the campaign against Iran that Treasury launched the same day. Treasury’s announcement described them as general licenses that “previously authorized certain remittance payments to Iran and Iranian access to the U.S. cultural and academic system.”

The same announcement designated nearly 60 entities, individuals, and vessels and made sector determinations under Executive Order 13902 covering digital assets, technology, gold, aviation, and shipping. OFAC has kept going since. On September 8 it suspended more ITSR authorizations, covering overflight payments, aircraft-safety licensing, bunkering and emergency repairs, and civil aircraft on temporary sojourn in Iran. On September 17 it designated BitBank, an Iranian digital-asset exchange, along with its developer and three individuals.

General License G was issued in March 2014 and published in the Federal Register that August (79 FR 49157). The text OFAC published covered, among other things:

Alongside the suspension, OFAC issued General License BB. It authorized transactions “ordinarily incident and necessary to the wind down” of anything previously authorized under the five suspended authorizations, through 12:01 a.m. eastern daylight time on September 8, 2026, on the condition that any payment to a blocked person went into a blocked, interest-bearing account in the United States (91 FR 55265).

General License BB did not authorize new activity. It gave institutions about two weeks to close out what was already in motion. That window has closed. Transactions that depended only on the suspended authorizations are no longer authorized by them.

A specific license is a written authorization OFAC issues to a particular applicant for a particular activity. After August 24 it was the obvious route for anything the suspended general licenses used to cover. OFAC’s September 10 Statement of Licensing Policy on Iran-Related Requests changes what an applicant should expect:

• It establishes a presumed denial for requests to engage in activity the ITSR prohibits.
• Iran-related specific licenses may only be issued as required by law or in exceptional and urgent circumstances, such as risk to life, limb, or environmental safety.
• Applicants should provide a written attestation demonstrating those circumstances.
• OFAC reviews each application case by case, in consultation with the State Department.
• It suspends earlier Statements of Licensing Policy that had given certain activities a favorable licensing posture.

Students already in the United States. OFAC did not suspend 31 CFR 560.505. It authorizes people in the United States on certain visas, including F, J, and M student and exchange visas, to carry out the activities their visa was granted for. An Iranian student already enrolled here on a student visa is not in the same position as an applicant in Tehran.

How the money moves. This is the open question, and we are not going to guess at it. The text of 560.505 does not address payments arriving from Iran, and 560.550, which covered noncommercial family remittances, is suspended. How a family in Iran pays tuition or living costs for a student in the United States is now a case-by-case question for sanctions counsel.

Nationality is not the test. General License G’s school provisions turn on where a person is located or ordinarily lives, not on citizenship. A rule keyed to nationality alone gets it wrong in both directions: it treats an Iranian citizen who has lived in Canada for a decade like an applicant in Tehran, and it misses a non-Iranian applicant who lives in Tehran.

For the broader licensing picture across other sanctions programs, see our OFAC licensing guide for schools.

None of this is a statutory checklist, and it is not legal advice. It is the operational work that lets a school show, later, that it noticed the change and handled it on purpose:

Most people in Iran appear on no sanctions list. The General License G suspension is about where a transaction goes, not whether a name matches the SDN List, so a clean name screen does not answer it. That question belongs to the facts a school collects and the judgment of its counsel.

Screening answers the other half: whether a student, sponsor, agent, or payer is a designated person. That half is getting busier. Operation Economic Outcast has added designations since August 24, and a family, sponsor, or payment intermediary that screened clean at admission can be designated later. A school needs both checks, and a record of both.

SecurePoint Education screens the students, tuition payers, sponsors, and donors a school manages against OFAC’s lists, sends possible matches to a person for review, and keeps the decision, the reviewer, and the supporting evidence on one record. Its licensing tools support the school’s review. They do not decide whether an authorization applies, and SecurePoint does not file anything with OFAC. Those calls stay with the school and its counsel. More on tuition payer screening and screening international students.