Through the accompanying FAQs, OFAC notes that: expands the case-by-case licensing policy for activity not covered by GL D-2 to specifically include “other activities to support internet freedom in Iran, including development and hosting of anti-surveillance software by Iranian developers” in an effort to encourage Iranian developers to create homegrown anti-surveillance and anti-censorship apps.
changes the stipulation that software be “necessary” to services incident to the exchange of communications over the internet, requiring only that it be “incident to, or enable” such services and. 
(This change is in line with a similar general license in the Cuba program)
removes the requirement that authorized communications be “personal” in nature, which, according to OFAC, is intended to ease the compliance burdens for companies seeking to verify the purpose of communications. GL D-1 only listed instant messaging, chat and email, social networking, sharing of photos and movies, web browsing, and blogging as authorized categories of software/services now authorizes additional categories of fee-based or no-cost software/services, including social media platforms, collaboration platforms, video conferencing, e-gaming, e-learning platforms, automated translation, web maps, and user authentication services, as well as cloud-based services in support of such services. More specifically, GL D-2 expands the scope of the prior authorization under GL D-1 to provide the Iranian people with more options for internet platforms and services. According to the accompanying press release, GL D-2 aims to support internet freedom in Iran by updating US sanctions guidance in light of changes in communications technology since the issuance of GL D-1 in 2014 and to respond to the Iranian government’s efforts to suppress internet access following recent anti-government movement in Iran. GL D-2 authorizes a more expansive set of internet communication-related activities, including cloud-based software and services, that are otherwise prohibited under the Iranian Transactions and Sanctions Regulations (“ITSR”). 
On September 23, 2022, the US Department of the Treasury’s Office of Foreign Assets Controls (“OFAC”) issued Iran General License D-2 (“ GL D-2“), which amends and replaces the former Iran General License D-1 (“ GL D-1“), and published three related Frequently Asked Questions (“ FAQs“).
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