OFAC FAQ (Current) # 1087 - Iran Sanctions (PDF contains all versions)

Date issued: May. 16 2024

Last substantive commentary amendment:
May. 17 2024

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TURBOFAC Commentary (513 words)

Notes:

* FAQ amended on 5-16-24 in connection with OFAC’s incorporation of Iran GL D-2 into the ITSR at section 560.540. Changes to the FAQ appear limited to certain non-substantive conforming amendments.

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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...