Educational Testing Service paused TOEFL and GRE administration in Iran on Tuesday 1 September and cancelled booked appointments, saying the step "reflects our full compliance with US sanctions law". Duolingo barred its English Test from anyone holding Iranian government-issued identification anywhere in the world, which is wider than the geographic scope of the OFAC action it cited1. A Telegram group for Iranian TOEFL candidates has 25,000 members. "It feels like they are taking Iranians out of the list of accepted human species," a Tehran resident identified only as Danial told Al Jazeera.
An Iranian passport holder living in Toronto or Berlin sits outside the jurisdiction the suspension describes and inside Duolingo's rule anyway. English-language certification of this kind gates university admission in most of the anglophone world, so a bar on both tests closes the application cycle for people whose only connection to the sanctioned territory is the document in their pocket.
A firm that reads a sanction too broadly faces no penalty for the excess; a firm that reads it too narrowly faces an enforcement action, and OFAC settled with a US weighing-equipment manufacturer for $60,764 last month over its Italian subsidiary's exports through a third-country distributor. Compliance departments price that asymmetry into every marginal call.
The consequence outlasts the cause. Restoring the general licence would not automatically restore the test, because the company's bar rests on its own terms of service rather than on the regulation, and there is no appeal to Treasury against a private reading of a Treasury rule.
