PAAIA is taking action to ensure that measures directed at the Islamic Republic of Iran do not become restrictions on American citizens and lawful permanent residents because of their Iranian heritage, national origin, place of birth, or historical ties to Iran.
Sanctions compliance is necessary. American institutions have an obligation to comply with U.S. law. But compliance must be based on what the law actually requires and on accurate, current information—not assumptions based on Iranian nationality, national origin, heritage, place of birth, or where someone once lived.
That distinction prompted PAAIA’s September 11 letter to the Law School Admission Council (LSAC) and accompanying public statement. PAAIA has received reports that U.S. citizens and lawful permanent residents have been denied access to LSAC services, including American citizens who have never set foot in Iran.
A Familiar Burden for Iranian Americans
For nearly half a century, Iranian Americans have lived with the consequences of the tensions between the United States and the Islamic Republic. Following the 1979 revolution and hostage crisis, Iranian students in the United States were required to report to federal immigration authorities and document their legal status. More than two decades later, following September 11, Iranian nationals were again subjected to special federal registration under the National Security Entry-Exit Registration System (NSEERS). In the intervening years and since, Iranian Americans have faced bias and discrimination in communities across America.
For a multigenerational community shaped by revolution, war, displacement, immigration, bias, and discrimination, that history matters. The problem has not been confined to government action or individual prejudice. Iranian Americans have encountered sanctions-compliance practices by financial institutions and businesses that imposed additional scrutiny and restrictions because of connections to Iran. Wells Fargo, for example, faced complaints over account closures and an “Iran Declaration” imposed on some customers of Iranian heritage.
Now PAAIA is hearing a troublingly familiar story from individuals dealing with LSAC.
Sanctions Compliance Cannot Become Identity Screening
LSAC reportedly informed affected individuals that it was “prohibited from providing any products or services to Iranian citizens or residents.” But Iranian citizenship, national origin, heritage, place of birth, or historical residence is not synonymous with current residence in Iran or sanctions status.
In one case brought to PAAIA’s attention, an individual opened his LSAC account while living in Iran more than a decade ago. He subsequently immigrated to the United States, attended an American law school, became a practicing attorney, and became a U.S. citizen. Yet his account was reportedly restricted based on residency information more than a decade old.
U.S. sanctions against the Islamic Republic of Iran should not result in American citizens and lawful permanent residents being denied opportunities in their own country. Sanctions compliance must be based on the law and accurate, current information—not nationality, national origin, heritage, or outdated assumptions about where someone lives.
The Cost Goes Beyond a Closed Account
For Iranian Americans, incidents like these do not occur in a historical vacuum. When an American citizen is subjected to additional scrutiny, has a bank account restricted, or encounters an educational barrier because of Iranian heritage, national origin, place of birth, familial connections, or outdated information, the message can be unmistakable: American citizenship may not prevent Iranian heritage or origin from making someone suspect without more.
That is particularly jarring given how deeply Iranian Americans are woven into American life. Across generations, Iranian Americans have helped build and shape communities from Minnesota to Florida, Oklahoma to New York City, Los Angeles, Silicon Valley, and beyond. We have founded businesses, treated patients, financed enterprises, developed technologies, constructed homes and infrastructure, practiced law, taught students, and served the public. Iranian Americans are physicians, scientists, engineers, entrepreneurs, financiers, builders, lawyers, educators, public servants, and members of the U.S. military.
Iranian Americans are not outsiders to the American story. We have helped build America.
Yet repeated experiences of being treated as suspect continue and can erode trust in American institutions and discourage participation in law, government, politics, public service, and public policy. A young American of Iranian heritage considering law school should not have to wonder whether a parent’s birthplace, an old address, dual citizenship, or another connection to Iran will create an additional obstacle.
For a multigenerational community that has experienced revolution, war, migration, post-1979 registration, post-9/11 special registration, and recurring bias and discrimination, repeated institutional barriers can deepen marginalization and transmit distrust across generations.
That is why PAAIA’s letter to LSAC matters.
PAAIA is asking LSAC to restore access to those legally eligible for its services, protect applicants from missed testing and admissions deadlines, and ensure that Iranian heritage, citizenship, national origin, place of birth, or outdated information is not improperly used as a proxy for residence or sanctions status.
Sanctions compliance is necessary. Discrimination is not.
The United States can enforce sanctions against the Islamic Republic of Iran without marginalizing Americans of Iranian heritage. Iranian Americans should not repeatedly bear consequences intended for the Islamic Republic of Iran.
American citizens should not have to prove that their Iranian heritage makes them any less American.
If you would like to contact LSAC, you may do so respectfully by email via [email protected] or by phone at (215) 968-1101