U.S. Department of the Treasury

Satellite terminals and other equipment listed in category (4) of the Annex to GL D-2, shall be deemed “residential consumer” if the equipment is designated EAR99 or classified under ECCN 5A992.c, 5A991.b.2, or 5A991.b.4 or, in the case of equipment that is not subject to the EAR, would be designated EAR99 if it were located in the United States or would meet the criteria for classification under ECCN 5A992.c, 5A991.b.2, or 5A991.b.4 if it were subject to the EAR. 

Date Updated: January 11, 2023

“Software required for effective consumer use” consists of software essential to the operation of the hardware listed in category (5) of the Annex to GL D-2 , including, for example, drivers and patches. Operating systems are separately authorized in category (5) of the Annex to GL D-2.

Date Updated: January 11, 2023

Yes.  Paragraph(a)(1) of GL D-2 authorizes the exportation to Iran of fee-based cloud computing services that support the exchange of communications over the internet.  In addition, paragraph (a)(2)(i) authorizes software that is incident to, or enables services incident to, the exchange of communications over the internet, and paragraph (a)(3) authorizes software described in the Annex to GL D-2 and services necessary for the operation of such software, in both cases provided that such software is designated EAR99 or classified by the U.S. Department of Commerce on the CCL under ECCN 5D992.c or, in the case of software that is not subject to the EAR, would be designated EAR99 if it were located in the United States or would meet the criteria for classification under ECCN 5D992.c if it were subject to the EAR.  Please see FAQ 1087–1089 for additional guidance. 

Date Updated: January 11, 2023

Yes.  Fee-based desktop publishing software and productivity software suites have been determined to fall within the scope of fee-based software that enables services incident to the exchange of communications as described in paragraph (a)(2) of GL D-2, provided that the software meets the additional criteria in those paragraphs (e.g., for software subject to the EAR, the software is designated EAR99 or is classified by the U.S. Department of Commerce on the Commerce Control List, 15 CFR part 774, supplement No. 1 (“CCL”) under ECCN 5D992.c).  By contrast, enterprise management software has been determined not to fall within the scope of fee-based software that enables services incident to the exchange of communications as described in paragraph (a)(2) of GL D-2.

Date Updated: January 11, 2023

SSLs, as described in category (11) of the Annex to GL D-2 encompass “provisioning and verification software for Secure Socket Layer (SSL) certificates designated EAR99 or classified under ECCN 5D992.c, and services necessary for the operation of such software.”  Additional provisioning and verification software not subject to the EAR may be included under GL D-2’s authorization for, in relevant part, software not subject to the EAR that is exported or reexported, directly or indirectly, by a U.S. person located outside the United States, that is of a type described in the Annex to GL D-2, provided that it would be eligible for classification under an ECCN listed in the Annex (ECCN 5D992.c), or designated as EAR99, if it were subject to the EAR.

Date Updated: January 11, 2023

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

Yes.  Accessories for use in conjunction with hardware specified in categories (1) and (5) of the Annex to GL D-2 , and peripherals for use in conjunction with hardware specified in category (5) of the same are authorized for export to Iran under GL D-2.  Authorized accessories for mobile phones include headsets, cases, holsters, mounts, chargers, docks, display protectors, cables, adapters, and batteries.  Authorized accessories for computers include keyboards and mice; authorized peripherals for computers include consumer disk drives and other data storage devices.  As set forth in a note to the Annex to GL D-2, for the purposes of the Annex, the term “consumer” refers to items that are: (1) generally available to the public by being sold, without restriction, from stock at retail selling points by means of any of the following: (a) over-the-counter transactions; (b) mail order transactions; (c) electronic transactions; or (d) telephone call transactions; and (2) designed for installation by the user without further substantial support by the supplier.

Date Updated: January 11, 2023

No.  While the exportation of certain accessories and peripherals specified in categories (1) and (5) of the Annex to GL D-2 , is authorized under paragraph (a)(3) of GL D-2, the exportation of hardware parts or components is not.  Requests for specific licenses to export parts or components, including replacement parts, will be considered on a case-by-case basis.

Date Updated: January 11, 2023

Yes.  Paragraph (a)(3) of GL D-2 authorizes the exportation of certain anti-virus, anti-malware, anti-tracking, and anti-censorship software, as specified in categories (6), (7), and (9) of the Annex to GL D-2.

Date Updated: January 11, 2023

The exportation to Iran of apps that are designated EAR99 or classified under export control classification number (ECCN) 5D992.c, as specified in category (8) of the Annex to GL D-2, is authorized under the GL D-2, including apps downloaded via online app stores.

Date Updated: January 11, 2023