Frequently Asked Questions

1175. Are services related to application programming interfaces (APIs) that are incident to the exchange of communications over the internet authorized for exportation or reexportation to Cuba pursuant to OFAC regulations?

… Among these are API-related services incident to the exchange of communications over the internet. This authorization may include, for example, API services incident to, among other … subject to U.S. jurisdiction, of services to support the exchange of communications over the… Read more

441. Does 31 CFR § 560.540 of the Iranian Transactions and Sanctions Regulations (ITSR) authorize the provision of fee-based cloud computing services to Iran?

… of fee-based cloud computing services that support the exchange of communications over the internet. In addition, paragraph (a)(2)(i) of 31 CFR § 560.540 authorizes the provision to Iran … that is incident to, or enables services incident to, the exchange of communications over… Read more

1176. What level of due diligence are internet-based service providers expected to conduct to determine whether the intended recipients of an export or reexport are prohibited officials of the Government of Cuba, prohibited members of the Cuban Communist Party, or organizations administered or controlled by the Government of Cuba or the Cuban Communist Party pursuant to 31 CFR § 515.578(b)(1)?

… exports or reexports are excluded from 31 CFR § 515.578 pursuant to 31 CFR § 515.578(b)(1) , internet-based service providers subject to U.S. jurisdiction may reasonably rely on information … What level of due diligence are internet-based service providers… Read more

1040. Are transactions related to telecommunications and certain internet-based communications that involve persons designated pursuant to Executive Order 14024 authorized by Russia-related General License (GL) 25G?

… to the Russian Federation that are incident to the exchange of communications over the internet and that are prohibited by the RuHSR. With respect to software, hardware, and … of software, hardware, or technology incident to the exchange of communications over the … Read more

1177. What internet-based services can be exported or reexported from the United States or by persons subject to U.S. jurisdiction to prohibited officials of the Government of Cuba, prohibited members of the Cuban Communist Party, or organizations administered or controlled by the Government of Cuba or the Cuban Communist Party?

… a prohibited member of the Cuban Communist Party, as defined in 31 CFR § 515.338 , of certain internet-based services and services related to certain exportations and reexportations, as … What internet-based services can be exported or reexported from the United… Read more

338. With respect to the authorizations in 31 CFR § 560.540(a)(1) and (a)(2) of the Iranian Transactions and Sanctions Regulations (ITSR), what services and software are covered?

… 31 CFR § 560.540(a)(1) are those that are “incident to the exchange of communications over the internet,” as well as cloud-based services in support of such services or of any other … that is incident to, or enables services incident to, the exchange of communications over the… Read more

1185. What activities are considered prohibited “information technology (IT) consultancy and design services” under the determination, “Prohibition on Certain Information Technology and Software Services,” pursuant to Executive Order (E.O. 14071) (the “IT and Software Services Determination”)?

… and Software Services Determination: A U.S. service provider provides a Russian company with internet access. A U.S. service provider provides a Russian company with internet services. The delivery of internet services includes, for example,… Read more

185. What type of activities does the GHRAVITY E.O. target?

… and communication by electronic means, including transmission and display, including via the Internet. … and communication by electronic means, including transmission and display, including via the Internet. …

498. The Compliance Services Guidance states that a U.S. person may solicit information from covered persons and conduct research to make a determination as to the legality of transactions under U.S. sanctions laws. What are examples of research that would be allowable under the Compliance Services Guidance?

… U.S. persons may conduct research using the internet, including searches of commercial databases, as well as published reference materials … U.S. persons may conduct research using the internet, including searches of commercial databases, as well as published… Read more

1087. Does the general license at 31 CFR § 560.540 authorize the exportation of fee-based or no-cost cloud-based services and software to Iran that are used to support communications tools authorized by 31 CFR § 560.540?

… fee-based or no-cost cloud-based services incident to the exchange of communications over the internet. In addition, 31 CFR § 560.540(a)(2) authorizes the exportation to Iran of cloud-based … software that is incident to, or enables services incident to, communications over the… Read more

Frequently Asked Questions

Office of Terrorism and Financial Intelligence