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If the Iranian Student leaves the United States and goes home for holiday (one month and then returns to the U.S.), can they use a U.S. bank account and mail in a check from Iran to pay their U.S. Bills? In addition, can they go on-line in Iran and make a payment from their home in Iran on the web with a U.S. bank account? Or would they have to wait until they return to the U.S. to make those transactions? The answers to these questions would be gratefully appreciated. Would the answer you provide me apply to the other sectorial sanction countries (Syria; Cuba; North Korea; and the Crimea region)?

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Gatta, Brian
Director - Sanctions, Inc.

Hi Eric,


The answers to these questions depend on a few variables, and the analysis is a bit different for every embargo program. 


One important variable is whether the students at issue would be considered by OFAC to be "ordinarily resident" in the sanctioned destinations to which they are travelling. As you may know, students from sanctioned destinations may retain their status as persons “ordinarily resident” in a sanctioned destination even while they are studying in the U.S. on a valid visa. The applicability of certain licenses turns on this “ordinarily resident” question. For all embargo programs except Cuba, sanctioned country citizenship is irrelevant. 


Another key variable, particularly in the Iran context, is the nature of the bills to which you are referring. If it is just student loans, there is a general license specifically for that in the Iran regulations (§ 560.551). For other types of bills, your answer might not necessarily be no, but the analysis changes.


Hope this helps,


Brian Gatta,



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