OFAC FAQ (Current) # 1088 - Iran Sanctions

Date issued: Sep. 23 2022

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TURBOFAC Commentary (252 words)

Notes:

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 "in support of [another] transaction authorized or exempt under the ITSR..." For example, the exportation of payroll management software (or any other cloud-based services) to an Iran-based scholarly journal could conceivably be authorized as...