June 20, 2024

OFAC updates three FAQs regarding the provision of humanitarian aid to Iran and Syria

On June 14, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control updated Frequently Asked Questions 828, 867, and 884.  FAQ 828 was updated to provide the public with information regarding the provision of humanitarian aid in response to public health concerns in Iran, including the COVID-19 outbreak.  OFAC confirms that humanitarian donations, including the donation of medications to relieve human suffering, are generally exempt from U.S. sanctions on Iran.  According to FAQ 828, broad exemptions, exceptions and authorizations also exist for the commercial sale and export of humanitarian goods, including medicine and medical devices, to Iran by U.S. persons and non-U.S. persons.  OFAC also provides a list of general licenses, FAQs and guidance offered for anyone, including nongovernmental organizations (“NGOs”), interested in providing health-related aid to and health-related services for the people of Iran.

OFAC also updated FAQ 867 to confirm that it is possible, under existing general and specific licenses in the Syrian Sanctions Regulations (“SySR”), 31 CFR Part 542, for U.S. and non-U.S. persons to provide humanitarian assistance to Syria following the designation of the Central Bank of Syria (“CBoS”).  According to FAQ 867, individuals and entities interested in providing humanitarian assistance or engaging in other permitted trade arrangements with Syria should continue to apply for licenses as they did prior to the CBoS’s designation.  OFAC also reiterated that it has a longstanding licensing policy that supports the provision of humanitarian assistance.  Furthermore, in its update to FAQ 884, OFAC confirmed that non-U.S. persons, including NGOs and foreign financial institutions, do not risk exposure to U.S. secondary sanctions under the Caesar Syria Civilian Protection Act of 2019 for activities that are authorized for U.S. persons under a general license issued pursuant to the SySR or for which U.S. persons would otherwise be exempt.

FAQ 828 | FAQ 867 | FAQ 884