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928. Do U.S. sanctions on the Taliban and the Haqqani Network prohibit the provision of humanitarian assistance to Afghanistan?
No. The Taliban are designated as a Specially Designated Global Terrorist (SDGTs) under Executive Order (E.O.) 13224. The Haqqani Network is designated as an SDGT under E.O. 13224 and a Foreign Terrorist Organization (FTO) under section 219 of the Immigration and Nationality Act (INA). These sanctions do not prohibit U.S. persons from exporting or reexporting goods or services to Afghanistan, provided that the transactions do not involve sanctioned individuals or entities, or property in which a blocked person has an interest unless exempt from regulation or authorized by OFAC.
In addition, OFAC has issued Afghanistan-related General Licenses (GLs) 14, 15, 16, 17, 18, 19, and 20 under the Global Terrorism Sanctions Regulations, 331 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part...
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1) This FAQ was substantially amended on 2-25-2022 to account for the issuance of GL 20 GTSR/FTOSR General License 20, which appears to cover close to the entirety of what had previously been authorized by GLs 14-19.
2) The FAQ states that GLs 14-20 "do not authorize any debit to a blocked account on the books of a U.S. financial institution". The text of the GLs contain a proviso stating that that they do not authorize "[a]ny debit to an account on the books of a U.S. financial institution of any blocked person". To the extent that "of any blocked person" may be seen as narrower than the full range of accounts blocked due to a blocked person's "interest" therein, this FAQ appears to resolve the ambiguity.
3) The original FAQ contained the...