Case No. IA-2018-353920-1

Date issued: May. 10 2019

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TURBOFAC Commentary (196 words)

Notes:

1) Compare Case No. IA-2018-XXXXX-X, which is substantially the same guidance letter, but here the subject is “a free app that provides a platform for aggregated sales of goods and commodities on various social network platforms,” which is decidedly less clear a fit for a “personal communications” GL than is the “messenger app” described in the other guidance letter.

Here, with the reference to "paragraph (a)(3) of GL D-1 and item 8 of the Annex to GL D-1," OFAC appears to take the view that Shopgram would qualify for the GL, but for the fact that it is an app of Iranian-origin. For more on the scope of these GLs as applied to software, see General Note on Prohibitions, Licenses and Exemptions as Applied to Social Media and Other Communications-Related Internet...