I don't think this has anything to do with ITAR. It's a sanction that includes export restrictions, but it's a completely different law. I think the law you w

I don't think this has anything to do with ITAR. It's a sanction that includes export restrictions, but it's a completely different law. I think the law you want to focus on is: CISADA (Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010). ITAR is just one of several export control laws in the US. The Export Administration Regulations (EAR) is another. In most cases these don't interfere with international software development... but sometimes they do. I don't think Microsoft has a choice here.