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Tell HN: You can now sell some software and services to Iranian customers
It's probably naive to think I can ensure the compliance of this myself, but as I have a US corporation, and use Stripe, and a US bank, I'm trying to make my way through the D-2 General license announced Sep 23 2022 to understand what I can and can't now do.
I have a remote browser isolation product that a few months ago a customer in Iran requested under dozen seats of. I told them I couldn't serve them at that time because of the sanctions. When I saw Blinken's tweet the other day[0], I thought of my potential Iranian customer, and emailed them to check-in. They said they were still happy and now had needed an order of magnitude more than before.
I started reading through the press release / license text[1] to try to make sense of it. It certainly seems like what I offer is covered.
I soon realized however that Stripe and my bank would likely consider transacting with Iranians a violation of their terms, understandably, as I don't think "financial services" are a covered business in these general licenses. In light of that, it may make it impossible to get paid. Then I hit on an idea: what if I use cryptocurrency? So that's my current heading.
Even so, I still need to verify if this person, their company, and their customers are not affiliated with the Iran government, and not on a blocked or restricted list. I don't really want to go through the personal details of people (it seems unnecessary from a product sales point of view), but it's part of ensuring compliance with OFAC and other restrictions, so I'm going to do it.
Even if that's all good, there's still other agencies that may restrict exports.
It's a minefield, but I think it's worth it to at least consider as well as I can, how I may be able to provide these folks with the services and products they want.
Anyway, I just wanted to PSA this news (I don't think many are aware of it, despite it being a big thing), and share my experience so far.
[0]: https://twitter.com/SecBlinken/status/1573327474951438337
[1]: https://home.treasury.gov/system/files/126/iran_gld2.pdf
- Our_Benefactors 4y ago> It's a minefield, but I think it's worth it to at least consider as well as I can, how I may be able to provide these folks with the services and products they want. “Worth it” in monetary terms? Or in social justice points? The risk/reward is totally out of whack here for providing generic Saas offerings.
- graderjs 4y agoAgree. I'll rethink this. Thanks! :)
- O__________O 4y agoMy suggestion is if this is of interest to you to identify companies that have gone through the process, identify the specific people with those organizations that enabled this, and connect with them to see if they have any specific and reusable advice.
- graderjs 4y agoMaybe, but I have no idea how to find those companies, or even if this would work: the risks may not be solvable with advice. Anyway, I probably won't do this now, but if you say how you would go about finding those companies, I think it would help your suggestion, for anyone who may want to pursue.