To the Office of Foreign Assets Control, US Department of the Treasury
Re: Objection to the Indefinite Suspension of Iran General License G (Effective August 24, 2026) — Denial of Access to English-Language Proficiency Examinations and Nongovernmental Scientific Exchange
I am writing to formally object to the indefinite suspension of General License G, effective August 24, 2026, and to urge its immediate reinstatement — at least, insofar as it authorized the administration of standardized academic and English-language examinations such as the TOEFL for Iranians, as well as nongovernmental academic and scientific exchange activities, regardless of an individual's current location.
General License G existed because past administrations recognized that academic exchange, independent scientific collaboration, and educational testing serve broader human and scientific interests, separate from the state of political relations between the two countries. Its suspension does not distinguish between government-linked activity and the independent, nongovernmental exchange of ideas between individual researchers, students, and institutions. Nor does it distinguish based on where an Iranian national happens to be located — the underlying identity document, not physical presence, is often what triggers restrictions in practice. The effect falls on individual students and scientists holding Iranian identity documents, many of whom have spent years preparing for university admission, joint research, scholarships, or professional licensure, entirely apart from matters of state policy.
I ask OFAC to consider three points:
1. This measure is overbroad, because it does not distinguish between government conduct and nongovernmental, individual-level activity, nor between nationality and current residence. Students seeking to demonstrate English proficiency, and researchers pursuing nonpolitical scientific collaboration, are private individuals engaged in education and inquiry — not agents of any government — whether they are located in Iran or hold Iranian identity documents while residing elsewhere. Suspending a private, US-based nonprofit's ability to administer an exam, or blocking academic and scientific exchange between individual researchers, does not meaningfully affect matters of state; it forecloses opportunity for individuals and institutions with no role in those matters.
2. This measure is impractical, because it is unlikely to achieve its intended policy objective while bearing real costs. Blocking standardized testing and nongovernmental scientific exchange does not exert pressure through any channel connected to state decision-making; instead, it drives students researchers and toward black-market testing alternatives, fraudulent score reporting, or third-country workarounds, and it has several long-standing nongovernmental scientific relationships that have often continued productively across periods of political tension.
3. This measure is humanitarian in its cost, because it closes off one of the few remaining lawful paths by which individuals can pursue education, scholarships, joint research, and professional futures abroad. For many applicants, testing windows and research timelines are narrow and cannot simply be delayed without losing a year of academic progress, a scholarship deadline, or a collaborative research opportunity. I write as someone directly affected by this closure, as an Iranian national.
I respectfully request that OFAC exempt standardized academic and English-language testing services, along with nongovernmental scientific and academic exchange activities, from the suspension for all individuals holding Iranian identity documents — whether located in Iran or elsewhere — or issue a specific license mechanism allowing these activities to continue without delay for individuals and institutions engaged in nonpolitical, individual-level exchange.

 
Thank you for your consideration.