On June 14, 2023, the US Department of the Treasury’s Office of Foreign Assets Control published a Fact Sheet on trade and humanitarian assistance intended to combat COVID-19 by ensuring that COVID-19-related assistance continues to reach at-risk populations in sanctioned countries, including Iran, Venezuela, North Korea, Syria, Cuba, and Russia. According to the Fact Sheet, OFAC stands ready to provide guidance regarding humanitarian assistance intended for these countries; to highlight the most relevant exemptions, exceptions and authorizations issued under these OFAC-administered sanctions programs; and to respond to applications for specific licenses as needed. The Fact Sheet also provides an overview of OFAC’s sanctions programs related to Iran, Venezuela, North Korea, Syria, Cuba, and Russia. OFAC urges persons interested in exporting Personal Protective Equipment (“PPE”) from the US to review all relevant US regulations, guidance and rules, including the temporary final rule issued the Federal Emergency Management Agency (“FEMA”) in 2020, which prohibits the export of five specific types of PPE from the US without FEMA approval, even though the temporary final rule has expired and all previous FEMA-related export restrictions are no longer in place.
OFAC also issued three new general licenses to extend authorizations related to certain COVID-19-related activities to June 14, 2023, pursuant to Syrian Sanctions Regulations (GL 21B), Venezuela Sanctions Regulations (GL 39B), and Iranian Transactions and Sanctions Regulations and the Global Terrorism Sanctions Regulations (GL N-2). OFAC also amended Frequently Asked Questions 906 through 911 to reflect the provisions of the new general licenses.