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August 30, 2007 

OFAC Expands Scope of General Licenses for Certain Publishing Activities (Sort of)

The Treasury Department's Office of Foreign Assets Control (OFAC) today issued a final rule in the Federal Register expanding the scope of activities allowed under the general licenses for publishing activities contained in OFAC's Cuba, Sudan, Iran and Burma sanctions regulations.

As a result of today's final rule, the general licenses relating to publishing activities permit the export and inclusion of embedded software necessary for reading, browsing, navigating or searching "written publications". In order to be eligible for the general licenses for Iran and Sudan, however, the embedded software must be classified as EAR99 under the Export Administration Regulations. The general licenses for Cuba and Burma now permit the export of such software if "
the exportation is licensed or otherwise authorized by the Department of Commerce under the provisions of the EAR".

The final rule also amends the various sanctions regulations by clarifying that the term "written publications'' used in the general licenses includes manuscripts, books, journals and newspapers even if they are published solely in electronic format.

OFAC's amendment of the Iran and Sudan general licenses relating to the export of embedded software for reading or browsing written publications does not appear to be a significant change in licensing policy. This is because even the most basic software products for reading or searching written publications are not classified as EAR99. For example, Adobe's on-line product matrix confirms that
Acrobat eBook Reader and Adobe Reader are classified as ECCN 5D992, since they contain encryption algorithms. Similarly, Microsoft's Internet Explorer is also classified as ECCN 5D992. Even Mozilla's Firefox is classified as ECCN 5D002.

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The Cuba and Burma amendments do not limit embedded software exports to EAR99, but to existence of authorization from Commerce for the exportation.

Thanks. That is an excellent point that is apparent only after a very close review of the amendments to the general licenses.

Do you know of any EAR99 software that would be eligible for the general licenses to Sudan or Iran?

Licensing software for export is a very difficult task. This is why regulations are really needed.

Armand Rousso

I could advise you a great software company Mr. Armand Rousso if you would like for Import / Export

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