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Financial Services Law Insights and Observations

OFAC issues and amends Iran-related FAQ

Financial Crimes Of Interest to Non-US Persons Department of Treasury OFAC OFAC Sanctions OFAC Designations Iran

Financial Crimes

On January 11, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) published an Iran-related frequently asked question (FAQ) and amended several other Iran-related FAQs. New FAQ 1110 clarifies Iran General License (GL) D-1 and GL D-2. Specifically, OFAC noted that because GL D-1 was issued in 2014, the types of software and services that support communication over the internet have changed. Therefore, to reflect technological developments in communication-related software and services since the issuance of GL D-1 (including in cloud-based services), OFAC issued GL D-2 to expand and clarify the range of U.S. software and services available to Iranians under OFAC’s sanctions program.