Notable Examples of Services and Software Regarded as Incident to “Personal Communications” or “Communications” Over the Internet for Internet Service GLs (System Note)

Last substantive commentary amendment:
Jun. 14 2024

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TURBOFAC Commentary (665 words)

Notable Examples of Services and Software Regarded as Incident to “Personal Communications” or “Communications” Over the Internet for Internet Service GLs

Read in conjunction with General Note on Prohibitions, Licenses and Exemptions as Applied to Social Media and Other Communications-Related Internet Services and Software (System Ed. Note), and particular section 5.

As discussed in the System Note, we assume that all software and services regarded as qualifying as incident to “personal communications” also qualifies as incident to “communications” generally where there is no “personal” qualifier. In some cases, items listed or determined to be covered by the “communications” GL may also be covered by the “personal communications” GL even if OFAC has not explicitly said so in a public setting (Case No. IA-17201-1, referenced below). In addition, note that in many cases the provision of "internet services" will...