After Mahsa Amini was killed in the custody of “Gasht-e-Ershad” or Iran’s Guidance Patrol, commonly referred to as Iran’s morality police, following an arrest for placement of her hijab, protests have erupted throughout Iran over women’s rights and Iran’s authoritarian regime more generally. Iran’s police and other security forces are retaliating severely against protestors. In response to these human rights abuses, on September 22, the U.S. Department of Treasury, Office of Foreign Assets Control (OFAC) sanctioned Iran’s morality police and senior leaders of Iran’s security organizations for the violence against protesters.
As protests spread, the Iranian government has also shut down the internet in an attempt to curb uprising. To address the internet restrictions, on September 23, OFAC updated General License D-2 on communications to increase support for internet freedom in Iran and provide the Iranian people with communication tools to exercise their ability to share information about what’s happening on the ground.
General License D-2 now clearly authorizes the export of fee-based or no-cost services for communications over the internet for instant messaging, social networking, web browsing, learning platforms, automated translation, web maps, video conferencing, social media platforms, user authentication services, and related communications cloud-based services to Iran. The license does not have an expiration date. Moreover, the related FAQs state that OFAC encourages persons to submit specific license applications for activities in support of internet freedom in Iran that are not authorized by General License D-2. In the FAQs, OFAC also clarifies its due diligence expectations for cloud-based or software service providers to evaluate end users when exporting to Iran.
The revisions to the general license facilitate the provision of communications tools to people in Iran. The revisions are intended to allow the Iranian people to develop and use anti-surveillance and anti-censorship technology. These revisions may substantially reduce the risk of certain technology, social media, cloud-based, and software company activities.
