31JUL

Duolingo bars any Iranian ID, anywhere

2 min read

09:44UTC

Educational Testing Service paused TOEFL and GRE administration in Iran and cancelled booked appointments. Duolingo went further, refusing its English Test to anyone holding Iranian identification anywhere on earth.

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Key takeaway

Duolingo's bar follows the passport, not the border the sanction actually describes.

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 cited ¹. 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.

Deep Analysis

In plain English

Two companies that run English-language tests reacted differently to the same US sanctions news. One stopped offering its test inside Iran. The other refused its test to anyone holding an Iranian government ID, anywhere in the world, even someone living in Toronto or Berlin who has never been to Iran. Companies often restrict more broadly than a sanction actually requires, because the legal risk of doing too little outweighs the risk of doing too much.

Deep Analysis

Root Causes

A private company faces real legal exposure for facilitating a transaction that turns out to violate sanctions, and essentially none for refusing service to more people than the law strictly requires. That asymmetry pushes compliance departments toward the broadest ban they can justify, not the narrowest one the sanction actually demands.

Duolingo's ban by nationality of ID, rather than by residence or transaction location, is a symptom of that incentive: it is far easier to check a document type than to verify a person is not using sanctioned financial rails.

Sources:Al Jazeera

Mentions:OFAC →Iran →Berlin →Al Jazeera →Telegram →Toronto →Tehran →

First Reported In

Update #175 · Iran says it re-mined the cleared lanes

Al Jazeera· 3 Sept 2026

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Causes and effects

Caused by

OFAC suspends five Iran general licences

Private companies read OFAC's licence suspension more broadly than its own text.

Occurred 23 Aug 2026

Read story →

This Event

Duolingo bars any Iranian ID, anywhere

A private company has extended an American sanction past the geographic reach of the instrument it cited, and no appeal reaches a company's own reading.

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