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ARTICLE · 26 APRIL 2010

OFAC Issues Tailored General Licenses Authorizing Certain Internet-Based Communications and Related Software Downloads

Wiley Rein
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The Department of the Treasury's Office of Foreign Assets Control (OFAC) has issued general licenses authorizing a limited set of free internet-based communications with persons in Cuba, Iran and Sudan.

United StatesIntellectual Property
Wiley Rein
Wiley Rein
Cari Stinebower
Cari Stinebower

The Department of the Treasury's Office of Foreign Assets Control (OFAC) has issued general licenses authorizing a limited set of free internet-based communications with persons in Cuba, Iran and Sudan.1  OFAC has simultaneously announced a policy to consider specific license requests for the export of communications-related services to Iran and Sudan.  This move appears intended to close the gap between the letter of the law and advances in internet-based communications. It also highlights OFAC's focus on "smart sanctions" that reduce the collateral impact of sanctions on persons living in sanctioned countries.  The focus on mobile communications also responds to concerns raised regarding the integrity of communications services in Iran available to Iranians protesting the June 2009 presidential elections.  It is not yet clear whether OFAC and the Department of State are ready to expand the scope of licenses for internet-based communications that are offered on

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