OFAC Issues Guidance for Recently Expanded Iranian General License
The Office of Foreign Assets Control published guidance this week on a September general license that expanded the types of internet and communications services and exports that can be provided to Iran (see 2209230037). General License D2 made several “key changes” to GL D1, OFAC said in a new frequently asked question, including language to “expand and clarify the range” of U.S. software and services that can be provided to Iranians.
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OFAC pointed to several differences between the two licenses, including that the agency removed the “personal” qualifier from GL D2, which had previously required certain services to be connected to “personal” communications to be covered by the license. The qualifier led to “compliance burdens for companies seeking to verify the personal nature of the communications supported by their software or services,” OFAC said.
The agency also stressed that it expanded its case-by-case licensing policy for activity not authorized by the general license to include “additional services that support internet freedom in Iran,” OFAC said, such as activities for developing and hosting anti-surveillance software by Iranian software developers. Those services also include developing and hosting “anti-censoring software” by Iranian software developers and exporting certain software development tools to Iranians “seeking to create their own anti-surveillance or anti-censorship apps and upload them to mobile app sites.”
OFAC also updated several other FAQs covering GL D2 and other Iran-related general licenses, including how they exempt certain online learning services, how OFAC defines certain items and equipment authorized under the licenses, and additional activities not authorized under the licenses.
When they announced GL D2 in September, Biden administration officials said they planned to continue talks with industry and issue more guidance to help companies understand what the license covers and whether it should be amended.