OFAC FAQ (Current) # 1087 - Iran Sanctions

Date issued: Sep. 23 2022

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TURBOFAC Commentary (487 words)

Notes:

1) See section 0.2(b)(i) of the commentary to Iran GL D-2. The addition of "no cost" services and software to GL D appears to have rendered 560.540 redundant.

2) This FAQ appears to take a broader interpretation of the authorization for “cloud-based services and software” than might otherwise be apparent from the text of GL D-2. OFAC says that “[f]or purposes of GL D-2, cloud-based services and software are determined to be incident to the exchange of communications over the Internet when they are used to support transactions authorized or exempt under the [ITSR],” including (e.g.) “transactions authorized pursuant to any general or specific licenses issued under the ITSR”. In other words, once it is determined that a given transaction is licensed “pursuant to any general or...