In response to the National Emergency declared by President Trump related to COVID-19 pandemic, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) published a fact sheet on April 16, 2020, to summarize all exemptions, exceptions and authorizations related to humanitarian assistance that may be provided under the Iran, Venezuela, North Korea, Syria, Cuba, and Ukraine/Russia-related sanctions programs, including the sale and export of personal protective equipment and various medications and medical devices that might assist with the treatment of COVID-19.
OFAC also encouraged any person or business affected by the pandemic that may be struggling to meet deadlines, such as delays in filing blocking and reject reports, responses to administrative subpoenas, and reports required under certain general or specific licenses, to reach out to OFAC as soon as practicable to discuss possible accommodations. OFAC also suggests that any self-disclosures be made via e-mail rather than physical mail.
Because OFAC understands that organizations may experience technical and resource challenges as a result of the COVID-19 pandemic, it emphasized its support for a risk-based approach to sanctions compliance. As a result, OFAC will consider any temporary reallocation of compliance resources caused by the pandemic as a determining factor when evaluating compliance-related offenses that may occur during this time. OFAC will address these issues on a case-by-case basis.