OFAC FAQ (Current) # 1088 - Iran Sanctions (PDF contains all versions)

Date issued: May. 16 2024

Last substantive commentary amendment:
May. 17 2024

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TURBOFAC Commentary (291 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. Amendments to this FAQ were non-substantive in nature.

---Below comments not amended as a result of the 5-16-24 amendments---

1) Read in conjunction with the broad guidance on the broad "cloud-based services and software" authorization at FAQ # 1087.

2) With the "payroll management software" example, OFAC appears to be distinguishing a case where "cloud-based services or software" are provided in support of (e.g. "instant messaging, chat, email, social networking, sharing of photos and movies, web browsing, blogging, social media platforms"), in which case they are inherently in support of covered transactions, and cases where the provision of such software would not necessarily be authorized, but could be authorized to the extent it were...