No. To qualify for GL D-2, all individual software items in a bundled package must fall within one of GL D-2 authorizations. If some software in a bundled package is authorized by GL D-2 but other software is not, the portion of the software falling outside the authorizations in GL D-2 would need to be otherwise exempt or authorized or would require a specific license for export. A bundle of software that included exclusively software authorized by GL D-2 and by 31 CFR § 560.540 could be exported. Please see FAQs 1087–1088 for guidance on certain types of cloud-based software authorized by GL D-2.
Date Updated: January 11, 2023