State Department Report under the Iran-Iraq Arms Non-Proliferation Act of 1992 re: Internet Services General License

Date issued: Dec. 15 2009

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TURBOFAC Commentary (101 words)

Notes:

1) Refer to FR Notice Explaining Introduction of Internet Services General Licenses (75 FR 10997, Mar. 8, 2010) for consolidated comment on both items.

2) Note the statement referring to "exemptions which already exist for the exchange of direct mail and phone calls". This is presumably a reference to the IEEPA personal communications exemption (560.210(a)).

3) Note the reference to "exchange of personal communications and/or sharing of information". The and/or, which does not appear in the OFAC GLs, may explain why the GLs have been interpreted to extend beyond that which could be strictly described as "personal communications".