Export News and Regulations

Educating the Enemy? MOOCs and U.S. Sanctions

For people throughout the world with limited access to higher education, online learning platforms have afforded opportunities that would otherwise be out of reach.

But recently, the number of people benefiting from those opportunities has shrunk. Coursera, a leading provider of free online university courses, has blocked students from Iran, Cuba and Sudan.

Limited Privilege

With over 21.5 million students from 190 countries, Coursera is one of the most popular MOOC (Massive Open Online Course) platforms in existence. But as a for-profit business (with fees for both certification and for hooking up employers with potential hires), they’re considered a service provider, and are now prohibited from dealing with countries under U.S. economic sanctions.

Coursera is working with the U.S. Department of State (DOS) and Office of Foreign Assets Control (OFAC) to reverse the controversial decision. Full access to their MOOCs has already been restored to previously-banned Syrian students (Under OFAC, Syria General License No. 11A authorizes services in support of nongovernmental organizations’ activities). In the meantime, social media is the vehicle for those directly impacted – and for those simply concerned – to express their outrage. Twitter is awash with derisive comments about the “terrorists winning” if we educate the Sudanese, and Facebook statuses of students in Iran pointedly question the “discriminatory” and “hateful” stance of the U.S. government.

Reading, Writing, Arithmetic and Export Compliance

By revoking MOOC access, the government has denied a segment of foreign students access to some of the most prestigious universities in the United States. Yet when foreign students are actually granted a study visa and permitted to come to the U.S., an education from Yale, Johns Hopkins, Princeton and others is possible.

The pairing of education and export compliance has never been simple. The work done at research institutions – involving controlled materials, equipment and technology – places universities at a high level of risk for deemed export violations. When controlled technology is released to a foreign person within the United States without proper licensing (aka Deemed Exports), it’s as much a compliance lapse as shipping a box of bullets abroad without authorization. The focus on the advancement of higher learning and making strides in scientific research must be balanced with stringent adherence to export regulations, particularly since it’s commonplace for schools to welcome foreign students, professors and other collaborators to their facilities.

The laws surrounding foreign students and their participation in research projects, classes and labs are complex. Technical information merely relating to the use of certain equipment – including operation, installation and maintenance – is controlled. Even if the course content includes such information, prior restricted party screening and an export license may be required to share it with a foreign student.

But when it comes to MOOCs, there is little cause for worrying about controlled equipment. Taking a gander at the Coursera course catalogue, the majority of the content appears harmless. Most of it seems to fall under the Educational Information Exclusion, under which no license is required to share with foreign persons “information concerning general scientific, mathematical or engineering principles commonly taught in universities or information in the public domain.” It’s fair game to share it verbally, post it online, or shout about it from the rooftops if that’s the way you roll.

Yet an eighteen-year-old kid in Cuba, armed with a laptop and a can of soda, listening to music while he wades through the maze of Algorithms, Part 1, is considered a threat to national security. Why?

That’s a question Coursera hopes will be answered before too many of their eager learners are driven to seek knowledge through some other means.