OFAC Amends General License to Aid the Free Flow of Information on the Internet in Iran
OFAC amended and expanded a General License authorizing certain transactions that support widespread access to the internet and freedom of expression in Iran.
The General License - GL D-2 - authorizes transactions relating to services, software and hardware incident to Internet-based communications. The changes include:
- expanding the scope of covered software/services to include social media platforms, e-gaming and e-learning platforms, and other digital media, as well as cloud-based services;
- authorizing services that support resisting internet censorship, including anti-virus and VPN software;
- removing the requirement that authorized communications must be "personal" in nature; and
- allowing for case-by-case evaluation of application licenses to support Iranian developers in creating anti-censorship technology.
The General License does not authorize (i) the provision of telecommunication services or devices, including satellites and web-hosting services, intended for use by the Iranian government or any designated individuals or entities on OFAC's SDN List; (ii) any action that would otherwise be prohibited or requires a license, or involves any person whose export privileges have been denied; and (iii) the transfer of funds from Iran or on behalf of a person in Iran unless the transfer is compliant with Iranian sanctions regulations.
OFAC also published three FAQs relating to the General License that addresses compliance limitations, exceptions and expectations.