59. Do I need an OFAC license to donate goods to sanctioned jurisdictions?
Some OFAC sanctions programs that broadly prohibit transactions involving an entire jurisdiction have exemptions or general licenses for certain donated goods, such as humanitarian articles, to relieve human suffering. For information on the exemptions and general licenses under a particular OFAC sanctions program, please see the relevant OFAC implementing regulations and the Sanctions Programs and Country Information page on OFAC's website.
Where humanitarian assistance-related transactions are not exempt or authorized pursuant to a general license, OFAC has long had a favorable specific licensing policy of supporting these types of transactions as necessary and appropriate (For background on the difference between a general and specific license, please see FAQ 74). OFAC prioritizes requests for specific licenses to provide humanitarian assistance and endeavors to review such applications expeditiously. OFAC encourages applicants to submit applications online (via the OFAC Specific Licenses and Interpretive Guidance Application page on OFAC's website) and to include a brief description of the proposed activities, the sanctioned jurisdictions or persons involved (including persons that appear on OFAC's sanctions lists, such as the Specially Designated Nationals and Blocked Persons List (the "SDN List")), as well as any risk mitigation measures that will be used to prevent potential violations.
Date Updated: September 9, 2026
Date Released
September 10, 2002
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59. Do I need a registration number or license to donate goods?
Most OFAC sanctions programs provide exemptions to their prohibitions for certain donated goods, such as articles to relieve human suffering. This is not the case for all programs, however. You should refer to the legal section of OFAC's website for the regulations applicable to the specific target or target country of your donation.
[Ed Note: see original FAQ for hyperlinks]
[9-9-26 Update – amended to highlight that “OFAC prioritizes requests for specific licenses to provide humanitarian assistance and endeavors to review such applications expeditiously,” and that applications should include “any risk mitigation measures that will be used to prevent potential violations.”]
1) See generally "Guidance Related to the Provision of Humanitarian Assistance by Not-For-Profit Non-Governmental Organizations." It appears that, to qualify for a license for which only NGOs are eligible, the organization would need to be a registered 501(c)(3) tax-exempt status organization. The registration number system that was in effect for the Sudanese Sanctions Regulations is no longer active.