On Thursday, February 27, 2020, OFAC released General License No. 8, Authorizing Certain Humanitarian Trade Transaction Involving Iran, which applies to the Iranian Transactions and Sanctions Regulations (ITSR) and the Global Terrorism Sanctions Regulations. GL-8 authorizes transactions and activities covered by the General Licenses set forth in Sections 530, 532, 533, 516, and 405 of the ITSR which involve the Central Bank of Iran (CBI). Despite the General Licenses in the ITSR, prior to GL-8 these transactions and activities were not authorized if they involved the CBI due to its designation on OFAC’s Specially Designated Nationals List. GL-8 was issued shortly after the announcement that the U.S. and Swiss had formally opened a humanitarian trade channel to Iran. Providing a general license authorizing the involvement of the CBI in exports of humanitarian aid to Iran should facilitate the use of the humanitarian channel, and is likely meant to counter criticism faced by the Trump administration related to the impact of the “maximum pressure” campaign on the average Iranian citizen.
Relevantly, GL-8 authorizes export and reexports of certain agricultural commodities, medicine, medical devices, and certain related software and services as well as transactions and activities ordinarily incident and necessary to those exports and reexports involving the CBI. This includes authorization for brokering commercial sales, payments and transfers of funds, arranging transportation, and financing of sales related to the export or reexport of agricultural commodities, medicine, medical devices, and certain related software and services.