The US Office of Foreign Assets Control has released a fact sheet on the most relevant exemptions, exceptions, and authorisations for humanitarian assistance and trade under the Iran, Venezuela, North Korea, Syria, Cuba, and Ukraine/Russia-related sanctions programmes.
The Fact Sheet also outlines specific guidance for OFAC-administered sanctions programs related to personal protective equipment (PPE) and other COVID-19-related humanitarian assistance and trade.
OFAC also states that it remains available to issue specific licences if necessary and confirms that non-US companies making medical products for use in Iran will not be considered to be operating in the manufacturing sector of the Iranian economy under secondary sanctions.
In a press release earlier this month, the US Treasury said that it “is committed to ensuring the international flow of humanitarian aid continues through legitimate and transparent channels.” However the Treasury also underscored that they “seek to mitigate the potential for this assistance to be diverted or misused by terrorists and other illicit actors.”
This is helpful guidance although it remains complex for non-profits and banks to navigate compliance.
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