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338. With respect to General License D-2 authorizations in paragraphs (a)(1) and (a)(2), what services and software are covered?

Answer

Qualifying services under paragraph (a)(1) are those that are “incident to the exchange of personal communications over the internet,” as well as cloud-based services in support of such services or of any other transaction authorized or exempt under the ITSR.  Qualifying software under paragraph (a)(2) is software that is incident to, or enable services incident to, the exchange of communications over the internet, as well as cloud-based services in support of the foregoing or of any other transaction authorized or exempt under the ITSR.  In addition, qualifying software under paragraph (a)(2) must meet the stated export control-related criteria.  Both paragraphs provide an illustrative but not exhaustive list of the types of services that are authorized: “instant messaging, chat and email, social networking, sharing of photos and movies, web browsing, blogging, social media platforms, collaboration platforms, video conferencing, e-gaming, e-learning platforms, automated translation, web maps, and user authentication services, as well as cloud-based services in support of the foregoing or of any other transaction authorized or exempt under the ITSR.”  See FAQ 344 and OFAC’s Interpretive Guidance and Statement of Licensing Policy on Internet Freedom in Iran (March 20, 2012), available at https://ofac.treasury.gov/system/files/126/internet_freedom.pdf

Qualifying services or software need not be specifically listed in the Annex in order to be authorized by paragraph (a)(1) or (a)(2), provided that they otherwise meet the requirements of paragraph (a)(1) or (a)(2).

Date Updated: January 11, 2023

Date Released
February 7, 2014