OFAC FAQ (Current) # 440 -Iran General License D-1 and 31 CFR § 538.533 for Sudan (the "Personal Communications" General Licenses)

Date issued: Feb. 17 2015

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TURBOFAC Commentary (1017 words)


1) For general discussion on GL D-1, see comment to Iran General License (No. D-1). See also ITSR GL D-1 and 560.540Scenario Matrix, Associated Comment. The Matrix identifies the scope of ITSR GL D-1 and 560.540 in the context of dozens of differing factual scenarios. Note that FAQs 434-443 are out of date to the degree that they assume the continued existence of the SSR (Part 538), which were repealed subsequent to the publication of the FAQs.

2) This FAQ is important as guidance on the scope of GL D-1 and, impliedly, all other internet services GLs.

OFAC characterizes "desktop publishing software and productivity software suites used to publish documents,...