I'm an iOS developer and one of my apps is a free app that targets Iranian user. The app is free with no ads. Apple asked me to provide an OFAC License to publish the app:

Dear Developer,

Thank you for providing this information. While we strive to make the App Store available to all developers, Apple must ensure compliance with U.S. sanctions laws before making apps available to customers. In order to proceed, please provide proof of approval from the U.S. Department of Treasury, Office of Foreign Asset Control (OFAC). Apple will accept a copy of the letter confirming release of your app from OFAC restrictions or a specific license from OFAC as proof of approval.

Once we have confirmed you have OFAC approval, you may submit apps for review. For more information on OFAC, you may want to visit the U.S. Department of Treasury’s website or the OFAC FAQ page. When you are ready to apply for OFAC approval, you will need to fill out the OFAC License Application.

I visited their website there but could not find out what kind of application I need, then I asked them via an email and it's their response:

Primary sanctions remain in force. Generally, U.S. persons are prohibited from engaging in direct or indirect commercial transactions with Iran without a general or specific OFAC license. Please see our FAQ page for more information about the status of the Iran Sanctions Regulations. You may apply for a specific transactional license from the OFAC License Application Page. Please be advised that it is necessary to outline details on the exact activity you would like to engage in, and as many details about the payment or financing for it as you can, when applying. Licenses will only be granted if they meet U.S. policy interests and there is no guarantee a license will issued.

Now I'm desperate and have no idea what to do! There are lots of other famous apps which serve Iranian users, all the major messaging apps, social networks, etc.

1 Answer 1


From the OFAC website:

Submitting an Application for a Specific License:

Applicants must first select the type of application that will be submitted from the following choices:

  • Application for authorization to travel to Cuba under a specific license. (Should your travel be authorized pursuant to a general license, do not submit an application for a specific license.)

  • Application for the release of a wire transfer blocked at a U.S. financial institution

  • Application for a specific license or interpretive guidance in all other circumstances (“Transactional”)

  • Application to export agricultural commodities, medicine, or medical devices to Sudan or Iran pursuant to the Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA)

It would appear that you need to apply for the third type of license: "Application for a specific license or interpretive guidance in all other circumstances (“Transactional”)."

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