IABA Statement on LSAC’s Compliance with Iran Sanctions

The Iranian American Bar Association is deeply concerned by the growing impact of recent changes to U.S. sanctions policy on ordinary Iranians, including students, families, professionals, and members of the Iranian diaspora.

On August 24, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) suspended several longstanding authorizations under the Iranian Transactions and Sanctions Regulations. These changes have already begun to affect access to educational, professional, and other services for Iranians, while creating substantial uncertainty regarding the scope of permissible activity under U.S. law.

The uncertainty alone can cause significant harm. Sanctions rules are complex, and when their scope is unclear, institutions and businesses often respond by imposing restrictions broader than the law requires. That risk is especially serious when institutions rely on Iranian nationality as a proxy for sanctions compliance, rather than undertaking the careful analysis necessary to determine whether a particular person, service, or transaction is actually restricted under U.S. law.

We are particularly concerned by reports that individuals, including those born or residing in the United States or Canada, have been restricted from accessing Law School Admission Council (LSAC) services because of their Iranian citizenship. As an organization of lawyers, IABA, in conjunction with the National Iranian American Law Student Association (NIALSA), its law student counterpart, is uniquely situated to understand the impact of these restrictions on access to the legal profession. Applicants prepare for the LSAT for months and organize their applications around specific testing dates and admissions deadlines. We have received reports of students losing access to their accounts during the LSAT testing window, being unable to take their scheduled examinations, and being prevented from submitting law school applications during a critical period in the rolling admissions cycle. Restoring access after the fact does not erase the disruption or remedy the harm. 

U.S. foreign policy objectives should not be pursued at the expense of the educational and professional opportunities of ordinary Iranians and members of the Iranian diaspora. OFAC should provide clear guidance on the scope of these measures, and institutions should ensure that their compliance practices do not impose restrictions beyond those required by U.S. sanctions law.

This statement reflects the position of IABA as an organization and does not represent the personal views of any individual member or chapter, unless specifically endorsed.