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951. Is Afghanistan subject to comprehensive sanctions?
No. In contrast to sanctions programs administered and enforced by OFAC with regard to North Korea, Cuba, Iran, Syria, and the Crimea and so-called Donetsk People’s Republic and Luhansk People’s Republic regions of Ukraine, there are no comprehensive sanctions on Afghanistan. Therefore, there are no OFAC-administered sanctions that prohibit the export or reexport of goods or services to Afghanistan, moving or sending money into and out of Afghanistan, or activities in Afghanistan, provided that such transactions or activities do not involve sanctioned individuals, entities, or property in which sanctioned individuals and entities have an interest.
Certain Afghanistan-related individuals and entities are included on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List), most notably the Taliban and the Haqqani Network. The Taliban are designated as a Specially Designated Global Terrorist (SDGT) under Executive Order (E.O.) 13224. The...
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1) FAQ Amended on 2-25-2022 to add non-substantive references to GTSR/FTOSR General License 20, to add "so-called Donetsk People’s Republic and Luhansk People’s Republic regions" to the list of comprehensively sanctioned areas, and to remove a paragraph stating that "Transactions or activities that involve [] sanctioned [individuals] persons or property in which such persons have an interest are generally prohibited, unless exempt from regulation or authorized by OFAC." This accounts for the scope of GL 20.
2) This FAQ appears to have been produced for the consumption of regulated persons not intimately familiar with the scope and operation of OFAC-administered sanctions laws. To the extent that anything in the FAQ could be construed as “guidance,” there are two notable aspects of the FAQ.
One is that we can discern that “moving or sending money into and out of Afghanistan”...