On February 25, 2022, the US Department of the Treasury’s Office of Foreign Assets Control issued a new Afghanistan-related general license along with 7 new and 17 amended Frequently Asked Questions to further clarify the impact of new general license.
OFAC issued General License 20, “Authorizing Transactions Involving Afghanistan or Governing Institutions in Afghanistan” to authorize any transaction that would otherwise be prohibited by the Global Terrorism Sanctions Regulations (GTSR), the Foreign Terrorist Organizations Sanctions Regulation (FTOSR) or the counterterrorism authority Executive Order 13224, as amended. According to OFAC, the purpose of GL 20 is to facilitate economic activity in Afghanistan and ensure that US sanctions do not prevent or inhibit transactions that are necessary to provide humanitarian aid to the Afghan people or the ability to support their basic human needs.
GL 20 specifically states that it does not authorize transfers to any blocked person, including the Taliban, the Haqqani Network or any entity in which they own a 50 percent or greater interest, unless it is for the purpose of paying taxes, fees, import duties, or related to the purchase/receipt of permits, licenses or public utility services, and only if the payments are not related to luxury items or services. It is important to note that nothing in GL 20 affects the property or interests of property of Da Afghanistan Bank that remains “protectively blocked” pursuant to EO 14064 of February 11, 2022.