Regulatory intelligence for US exporters

OFAC Restricts Types of Computers Authorized Under Iran General License

The Office of Foreign Assets Control is updating the scope of an Iran-related general license to limit the computing power threshold for laptops, tablets and other personal computing devices that can be exported or reexported to Iran. The agency also revised its Iranian Transactions and Sanctions Regulations to make “additional conforming changes.”

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OFAC said the change will update the list of items in the annex of General License D-2, which includes certain communications-related services, software and hardware that can be exported or provided to Iran. The new list “will restrict the computing power of laptops, tablets, and personal computing devices authorized for exportation or reexportation to Iran,” OFAC said. This will help “address concerns about the use of multiple, connected computing devices with increased computing powers to create high-powered computers,” the agency said in a final rule outlining the changes and other revisions to the regulations.

The agency published the new, updated list and also described the changes in two separate notices and a set of updated frequently asked questions. The agency also released a new FAQ to clarify the term "user authentication services" in General License D-2. The changes to the license take effect June 17.

OFAC originally issued General License D-2 in September 2022 to expand the types of internet and communications services and exports that could be provided to Iran (see 2209230037). A U.S. official at the time urged technology companies to use the license to give the Iranian people access to communication and internet tools (see 2210130003).

The final rule published by OFAC, which takes effect May 17, also makes other changes to the Iran regulations, including one that will address repair and replacement issues involving certain items sent to Iran and another that will authorize transactions for imports of certain hardware or software into third countries. Another change authorizes exports or reexports of certain services conducted outside Iran to install, repair or replace certain authorized hardware or software sent to Iran, and OFAC said those activities are allowed “only when the service provider is located outside Iran and does not authorize the service providers to engage in such services while in Iran.”

Another change refines and clarifies restrictions related to web-hosting services or domain name registration services in Iran, while other revisions officially incorporate previously made licensing policies, language, or updates into the Iranian Transactions and Sanctions Regulations.