Does 31 CFR § 560.540 of the Iranian Transactions and Sanctions Regulations (ITSR) authorize the export of bundled software that includes both software authorized by § 560.540 and software that is not authorized by § 560.540?

OFAC's answer

No. To qualify for [31 CFR § 560.540](https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-560), all individual software items in a bundled package must fall within one of the 31 CFR § 560.540 authorizations. If some software in a bundled package is authorized by 31 CFR § 560.540 but other software is not, the portion of the software falling outside the authorizations in 31 CFR § 560.540 would need to be otherwise exempt or authorized or would require a specific license for export. A bundle of software that included exclusively software authorized by [31 CFR § 560.540](https://www.ecfr.gov/current/title-31/subtitle-B/chapter-V/part-560) could be exported. Please see FAQs [1087–1088](https://ofac.treasury.gov/faqs/search/1087+1088) for guidance on certain types of cloud-based software authorized by 31 CFR § 560.540. Date Updated: May 16, 2024