Frequently Asked Questions

341. May a non-U.S. person export, reexport, or provide to Iran hardware and software that is subject to Commerce's Export Administration Regulations (EAR) pursuant to General License D-1?

Answer

Yes, for purposes of the authorities administered by OFAC, amendments made by General License (GL) D-1 authorize the exportation, reexportation, or provision of certain hardware and software subject to the EAR by non-U.S. persons outside the United States. See GL D-1, paragraphs (a)(2)(i) & (a)(3). For example, a non-U.S. person manufacturer of smartphones that are (a) subject to the EAR because they contain more than a de minimis amount of U.S. controlled content and (b) within the scope of the GL D-1 authorization may export the smartphones from its third-country manufacturing facility directly or indirectly to Iran. See FAQ 337.

Date Released
February 7, 2014