Distributing a free iOS app to Iranian users
<p>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:</p>

<blockquote>
  <p>Dear Developer,</p>
  
  <p>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. </p>
  
  <p>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.</p>
</blockquote>

<p>I visited their <a href="https://licensing.ofac.treas.gov/Apply/Introduction.aspx" rel="nofollow noreferrer">website</a> there but could not find out what kind of application I need, then I asked them via an email and it's their response:</p>

<blockquote>
  <p>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 <a href="https://www.treasury.gov/resource-center/sanctions/Programs/Documents/jcpoa_faqs.pdf" rel="nofollow noreferrer">Iran Sanctions</a>
  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.</p>
</blockquote>

<p>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.</p>

<p>From the OFAC website:</p>

<blockquote>
  <p>Submitting an Application for a Specific License: </p>
  
  <p>Applicants must first select the type of application that will be
  submitted from the following choices:</p>
  
  <ul>
  <li><p>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.)</p></li>
  <li><p>Application for the release of a wire transfer blocked at a U.S.
  financial institution </p></li>
  <li><p><strong>Application for a specific license or
  interpretive guidance in all other circumstances (“Transactional”)</strong></p></li>
  <li><p>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)</p></li>
  </ul>
</blockquote>

<p>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”)."</p>

united-states legal-terms export sanctions