OFAC FAQ (Current) # 348 - Compliance for Internet, Web Based Activities, and Personal Communications (PDF contans all versions)

Date issued: Jan. 11 2023

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TURBOFAC Commentary (672 words)

Notes:

* On 9-23-22, OFAC replaced Iran GL D-1 with Iran GL D-2, initially without making amendments to this FAQ. See Iran GL D-2, and comments thereto, for a discussion on the changes between GL D-1 and GL D-2. On 1-11-23, OFAC amended this FAQ without making substantive changes beyond, as the case may be, changing references to GL D-1 to GL D-2, removing "personal" from "personal communications", and adding references to certain new FAQs. The notes below the asterisks pertain to the original version of the FAQ (see native PDF file).

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1) Although this is not stated explicitly, OFAC apparently does not consider the use of any degree of on-the-ground marketing services to constitute a transaction "ordinarily incident" to the authorizations of GL D-1, which are permissible under 560.405...