On January 11, 2023, the Department of the Treasury’s Office of Foreign Assets Control issued 1 new Frequently Asked Question (FAQ 1110) and amended 22 others (FAQ 337-346, 348, 434-443, and 853) to reflect the changes in General License D-2, clarify the changes in comparison to General License D-1, and provide an overview of the GL’s pre-existing authorizations.
GL D-2 was issued by OFAC on September 23, 2022 pursuant to Iranian Transactions and Sanctions Regulations (“ITSR”), 31 CFR part 560, in response to recent internet restrictions imposed by the Government of Iran. According to OFAC, the Iranian government imposed the restrictions to prevent the world from witnessing the violent response to peaceful protests inspired by the death of Mahsa Amini while in the custody of Iran’s Morality Police. GL D-1, which was issued by OFAC in 2014, authorized US persons to export, reexport or provide certain communications-related services, software and hardware to persons in Iran, and GL D-2 expands the provisions in this license to cover certain technological developments that occurred since 2014, including social media and other collaboration platforms, video conferencing, and cloud-based services with communications-related functions.