ARTICLE
27 October 2014

OFAC Licenses Educational Activities In Sudan And Cuba

SS
Shearman & Sterling LLP

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In early September, Coursera, a provider of open online educational courses, received an OFAC license to reinstate its services in Cuba and Sudan.
United States International Law

On August 11, OFAC issued amended Sudan General License No. 1A to expand the scope of General License No. 1, issued April 15, 2013, to authorize certain academic and professional exchange activities otherwise prohibited under the Sudanese Sanctions Regulations. OFAC simultaneously published guidance to explain the changes made by Sudan General License No. 1A, which include: (i) the expansion of the definition of "US academic institutions" to include third-country branch campuses and contractors of those institutions; (ii) authorization for US academic institutions to engage in activities necessary for Sudanese nationals to apply to US academic institutions (e.g., accepting payments for tuition or admission application fees); and (iii) authorization for US financial institutions to process transfers of funds by Sudanese nationals to pay fees and expenses (including tuition, living expenses, and enrollment fees) to enable Sudanese nationals to participate in authorized academic exchange programs or professional training seminars.

In early September, Coursera, a provider of open online educational courses, received an OFAC license to reinstate its services in Cuba and Sudan. Coursera had blocked access to the two countries and Iran in January 2014 over concerns about sanctions liability; services to Iran were resumed in June. The OFAC license still bars Coursera from offering certain advanced science, technology, engineering, and math classes.

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