Collin Anderson writes for EA:

Last month, international outlets and Persian-language social media were abuzz with the news that Facebook and Twitter had been unblocked in Iran.

But that temporary “unblocking”, likely the result of technological failure than a sudden political u-turn, overshadowed a more complex story about Iranian access to the internet.

This is a story about how American technology companies — not the Iranian political system — are reducing Iranian access to the web. It is a story about how US corporations are imposing stringent sanctions against technology and the provision of information services to the Islamic Republic.


There are two levels of US sanctions against Iran. The first and best-known are the laws and executive orders adopted by the US Government.

The second level is the entangling set of risk-management decisions which those, tasked with complying with those laws, must address and undertake.

On a near-annual basis for three years now, the Departments of Treasury and State have rewritten the rules on technology exports to Iran. This year, General License D was released at the start of June, two weeks before Tehran’s Presidential election — on paper, it read as a wide authorization of online communications devices and services.

General License D also maintained confusingly-worded restrictions on web-hosting services and domain name registration services for purposes other than “personal communications”.

Moreover, some analysts noted that the use of a .ir domain could potentially qualify as an importation of service, which is not necessarily covered under the General License.

Managing risk, compliance lawyers have often advised that applications be withheld and websites blocked, thus preventing any penalties being imposed against their clients.


The outcome has been a mix of progress and setbacks. For example, Google discreetly announced the availability of the Play Store in Iran and the ability to target the Persian language in AdWords advertising. Apple quietly dropped prohibitions against distribution by resellers of its products to Iran.

At the same time, a substantial portion of the Internet remains unavailable to Iranians, as A shadow filtering regime is imposed internationally by web services blocking connections. GoDaddy and Google App Engine, two of the largest hosts of content on the Internet, completely block access, often without disclosure to customers or potential visitors.

[Editor’s Note: We celebrated last month when EA WorldView was unblocked in Iran for the first time since 2010. However, Collin Anderson soon informed us that the site is still beyond reach of Iranians, because of the restrictions of our US hosting company.]

In early August, the official site of detained opposition leader Mehdi Karroubi was removed by its host, Just Host, explicitly citing US sanctions. The site’s “offense” was the use of an .ir country-code domain and its registration to an address in Tehran, even though the account and domain were actually administered outside the country. The company has sought remedy through the lengthy process of applying for a specific license from the Office of Foreign Assets Control.

The decision of Just Host, a subsidiary of the strict sanctions enforcer Bluehost, exposes the problems of the General License and the US system. For small web services companies attempting to remain in compliance with American law, it is nearly impossible to determine whether every hosted website in the Persian-language or customer with an Iranian passport is exempt from the restrictions.

Karroubi’s site, like many others, is still off-line in Iran.


As with medical items and other humanitarian goods, the core concern of compliance personnel often revolves around the legality of financial transactions. So Google Play Store in Iran remains limited to applications that are free.

OFAC’s July “Guidance on the Sale of Food, Agricultural Commodities, Medicine, and Medical Devices by Non-U.S. Persons to Iran”, which nominally loosened restrictions on movement of those products to the Islamic Republic, made no reference to payments for technology items.

In March 2012, OFAC issued an “Interpretive Guidance and Statement of Licensing Policy on Internet Freedom in Iran”, an initiative which was the centerpiece of Obama’s annual Nowruz outreach to the Iranian public.

Of the twelve products named, five had already been made available to Iranians, at least two from companies pursuing specific authorizations. One other, Dropbox, subsequently responded to the Treasury’s overtures.

And the other six — Adobe Reader, Flash Player, Shockwave, Java, Yahoo Messenger (Desktop Client) and Google Talk (Desktop Client)?

They are still out of reach of Iranians 18 months later.