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Does an Iranian citizen studying toward a PhD in the United States with an F1 visa need to obtain an export license (or some other paperwork in that spirit) to be able to work full-time for a company in the United States via Optional Practical Training (OPT)?

If that depends on the field, the field is machine learning applied to natural language processing.

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    Why would a legal resident in the US working in the US for a US company need an export license? Do they export anything? Is anything there remote work or data transfer outside the US?
    – nvoigt
    Commented Mar 9, 2022 at 10:44
  • @nvoigt no remote work or data transfer outside the US. Someone told me about it but perhaps was mistaken or didn't use the proper term, hence this question.
    – Franck Dernoncourt
    Commented Mar 9, 2022 at 15:13
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    I think it's more that the company needs to ensure that the OPT person not work with any export-controlled technology: colorado.edu/researchinnovation/ori-compliance/export-controls/…
    – mkennedy
    Commented Mar 9, 2022 at 16:06

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The need an export license to be able to work for a company in the US depends on the company and the job (including within the field machine learning applied to natural language processing: still depends on the company+job). It can affect both Curricular Practical Training (CPT) and Optional Practical Training (OPT). it's not needed for Iranian who is also a US lawful permanent resident (LPR). The hiring company takes care of everything but the Iranian hire needs to fill out a lot of papers for the export team.

This is echoed by Reddit user not_an_immi_lawyer:

Depends on your field. If you work in a sensitive field, especially around military, nuclear, robotics or AI, your employer may require an EAR/ITAR export license. Being an Iranian citizen, you have a high chance of being denied one. However, most jobs outside these fields generally do not require an EAR/ITAR, and you won't need one to work full-time for such employers.

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    This is incorrect. The student doesn't apply for a EAR/ITAR license, neither does any other employee. The organization applies, and needs to comply with the terms of the license (including, potentially, restricting access to certain employees). See for example here: bis.doc.gov/index.php/documents/technology-evaluation/…
    – littleadv
    Commented Mar 21, 2022 at 2:17
  • @littleadv thanks that's what I wrote "The hiring company takes care of everything but the Iranian hire needs to fill out a lot of papers for the export team.'
    – Franck Dernoncourt
    Commented Mar 21, 2022 at 3:08
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    You asked "Does an Iranian citizen ... with an F1 visa need to obtain an export license". The correct answer is NO.
    – littleadv
    Commented Mar 21, 2022 at 4:08
  • @littleadv " The hiring company takes care of everything but the Iranian hire needs to fill out a lot of papers for the export team" is a more informative answer. But feel free to write no as a separate answer if you think this adds anything to my answer.
    – Franck Dernoncourt
    Commented Mar 21, 2022 at 4:11
  • That's just plain wrong. I tried to write an answer, but "NO" is too short.
    – littleadv
    Commented Mar 21, 2022 at 4:17

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