On January 11, 2023, the U.S. Department of the Treasury's
Office of Foreign Assets Control ("OFAC") issued a new
Iran-related "Frequently Asked Question"
("FAQ") (available
here) regarding the implementation of Iran General License
("GL") D-2, issued by OFAC on September 23, 2022. In
addition to this new FAQ, OFAC also amended over twenty already
published Iran-related FAQs to address changes made in GL D-2.
GL D-2 supersedes the previously issued GL D-1, which addressed
certain services, software, and hardware incident to personal
communications. However, as OFAC has recognized, since the issuance
of GL D-1 in 2014, "the types of software and services that
support communication over the internet have changed." GL D-2
reflects these technological developments and is intended to both
expand and clarify what U.S. software and services are available to
Iranians pursuant to OFAC's sanctions program.
