Exempt Free Online Courses from United States Export Controls

The United States must remove barriers to free online courses in sanctioned countries. These online courses are a boon to American diplomacy and not a threat to national security.

By Nicole Bailey
Staff Writer
July 1, 2015

Note: this is a follow-up piece to the author’s previously published article, “MOOCs” The Next Foreign Policy Tool.”

International affairs professionals have only recently begun to realize the potential of free online courses as a foreign policy tool. After all, 3 million users enrolled 6.4 million times for edX, one major U.S.-based course provider, in 2014 alone.1 The level of engagement between students, teachers, facilitators, and other assistants is unprecedented and unparalleled; however, efforts to leverage online courses have been suppressed by shortsighted export control regulations.

President Obama should immediately issue an Executive Order removing unjustifiable barriers to free online courses in sanctioned countries. Implementing exemptions for free online classes will require time, interagency collaboration, and legal changes, but the U.S. government will reap the rewards for generations. The potential public diplomacy benefits are enormous, while the imagined threats to national security have been exaggerated.

Mostly based in the United States, free online courses draw participants from around the world. The proliferation of online classes, capable of enrolling tens of thousands of students simultaneously, has greatly increased education accessibility globally. These classes support American educational institutions, promote the nation’s image abroad, and inform foreign publics about American culture, values, and society. Consequently, free online courses can become a formidable public diplomacy tool for the U.S. government.

Despite these benefits, free online courses are legally defined as a service subject to federal export regulations. The Department of State and the Office of Foreign Assets Control of the Department of the Treasury enforce these restrictions, which largely aim to prevent hostile parties from gaining knowledge that could be used to threaten national security.2

According to the Restrictions web page of Coursera, the largest free online course provider in the world, the U.S. government requires an Internet Protocol (IP) address block for users in sanctioned countries. The block limits user access to content based on his or her IP address, the identifying label of the device being used. Students in Cuba, Iran, and Sudan are currently only permitted to access certain parts of Coursera, and students in Crimea are blocked entirely.

Supporters of restricting U.S.-based online education access argue that training in certain subjects can aid individuals who intend to harm national security. Therefore, sanctions have been maintained on advanced science, technology, engineering, and math classes in particular.

Nevertheless, it is highly unlikely that credible threats are being mitigated by the current policy for two reasons. First, an individual in advanced science, technology, engineering, and mathematics classes is the least likely to be deterred by a simple IP address block. In addition, IP address block circumvention techniques are widespread even among non-expert citizens who seek access to Western entertainment or uncensored search engines. Second, there is no reason to believe that online course providers have a monopoly on potentially threatening information. A user, barred from learning about nuclear engineering on Coursera, can quickly and easily find the same information on Wikipedia, YouTube, or elsewhere online.

With little threat to national security interests, the sanctions should be removed to allow the Department of State to better leverage the public diplomacy benefits of free online classes. Since the change will be interagency in nature, only an immediately effective Executive Order from President Obama can begin to resolve the problem efficiently. Previously instated modifications of General Licenses that exempted some categories of free online classes serve as a useful precedent. General Licenses, which specify how federal export controls are applied to individual countries, are managed by the Office of Foreign Assets Control of the Department of the Treasury. Notably, the President can modify General Licenses by Executive Order.

President Obama should immediately issue an Executive Order with two mandates. First, the Department of the Treasury’s Office of Foreign Assets Control should immediately update the General Licenses for all sanctioned countries exempting all free online courses from U.S. export controls. Second, the Department of State’s Under Secretary for Public Diplomacy and Public Affairs Rick Stengel should create a temporary working group within four weeks. By the end of the quarter, the working group should present actionable recommendations on how to use free online learning as a public diplomacy tool in formerly sanctioned areas. Ultimately, this expansion of access will remove unjustifiable barriers to education and support greater U.S. public diplomacy abroad.


1. Shah, Dhawal. “Online Courses Raise Their Game: A Review of MOOC Stats and Trends in 2014.” Class Central. Accessed: 22 June 2015. Web. https://www.class-central.com/report/moocs-stats-and-trends-2014/

2. Straumsheim, Carl. “Massive Closed Online Courses.” Inside Higher Ed. Updated: 28 January 2014. Accessed: 9 June 2015. Web. https://www.insidehighered.com/news/2014/01/28/state-dept-blocks-access-...


Nicole Bailey is a first-year student in the Global Communication program concentrating in IT and Middle East Studies at the Elliott School of International Affairs. She graduated from the University of Virginia with a degree in Political Philosophy, Policy, and Law. She can be reached via Twitter @nsunebailey.

"Internet Map" by The Opte Project, is licensed under CC-BY-2.5.

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