439. Does 31 CFR § 560.540 of the Iranian Transactions and Sanctions Regulations (ITSR) authorize the export of bundled software that includes both software authorized by § 560.540 and software that is not authorized by § 560.540?

No.  To qualify for 31 CFR § 560.540, all individual software items in a bundled package must fall within one of the 31 CFR § 560.540 authorizations.  If some software in a bundled package is authorized by 31 CFR § 560.540 but other software is not, the portion of the software falling outside the authorizations in 31 CFR § 560.540 would need to be otherwise exempt or authorized or would require a specific license for export.  A bundle of software that included exclusively software authorized by 31 CFR § 560.540 could be exported.  Please see FAQs 1087–1088 for guidance on certain types of cloud-based software authorized by 31 CFR § 560.540.

Date Updated: May 16, 2024