Treasury Issues Iran General License D-2 to Increase Support for Internet Freedom

The Department of the Treasury issued Iran General License (GL) D-2 to increase support for internet freedom in Iran by bringing US sanctions guidance in line with the changes in modern technology since the issuance of Iran GL D-1. On Sept 21, the Iranian government cut off access to the Internet for most of its 80 million citizens to prevent the world from watching its violent crackdown on peaceful protestors sparked by the brutal death of Mahsa Amini in the custody of Iran’s Morality Police. While Iran’s government is cutting off its people’s access to the global internet, the United States is taking action to support the free flow of information and access to fact-based information to the Iranian people. The updated guidance will authorize technology companies to offer the Iranian people more options of secure, outside platforms and services. The expanded GL tackles the following key issues:

• Adds covered categories of software/services to include social media platforms, collaboration platforms, video conferencing, as well as cloud-based services in support of such services, as well as tools that incorporate communication functions and are often included with authorized items or services (e.g., online maps, e-gaming, e-learning platforms, automated translation, web maps, and user authentication services)
• Provides additional authorization for the services that support the communication tools to assist ordinary Iranians in resisting repressive internet censorship and surveillance tools deployed by the Iranian regime.
• GL D-2 continues to authorize anti-virus and anti-malware software; anti-tracking software; mobile operating systems and related software; anti-censorship tools and related software; Virtual Private Network (VPN) client software; and related software. These tools protect the ability of Iranians to engage in free expression and bravely resist regime oppression.
• Removes the condition that communications be "personal," which was resulting in compliance burdens for companies seeking to verify the purpose of communications.
• For activity not covered by GL D-2, expands existing case-by-case licensing policy, particularly to allow Iranian developers to create homegrown anti-surveillance and anti-censorship apps, which many Iranian people rely upon to circumvent domestic internet controls.