OFAC FAQ (Current) # 337 - Compliance for Internet, Web Based Activities, and Personal Communications (PDF contans all versions)

Date issued: Jan. 11 2023

Last substantive commentary amendment:
Apr. 03 2024

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TURBOFAC Commentary (285 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, changing the substance of it to simply convey that GL D-2 is, in all respects, at least as broad as GL D-1. The notes below the asterisks pertain to the original version of the FAQ (see native PDF file).

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1) Note that the reference to "in country" transfers does not appear in the GL, and that, when amending GL D, OFAC added the word "provision" to "...[t]he exportation, reexportation, or provision, directly or indirectly, to Iran..."

This is apparently meant to ensure that...