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954. Are purchases of fuel, payment for telecommunications services, payment for security services, payment of rent, and payment of utilities by nongovernmental organizations (NGOs) considered ordinarily incident and necessary to authorized activities under Afghanistan-related General Licenses (GLs) 14, 15, and 19? Are such transactions covered by Afghanistan-related GL 20?
The purchases of fuel, payment for telecommunications services, payment for security services, payment of rent, and payment of utilities may be authorized under 14, 15, and 19 provided that they are ordinarily incident and necessary to effectuate the activities authorized by the GLs. As with all OFAC GLs, GLs 14, 15, and 19 are “self-executing,” meaning that persons who determine that such activities are ordinarily incident and necessary to their authorized activity within the scope of the GL may proceed without further assurance from OFAC.
OFAC has also issued Afghanistan-related GL 17 to authorize all transactions...
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1) FAQ Amended on 2-25-2022 to add non-substantive references to GTSR/FTOSR General License 20.
2) The following statement:
"purchases of fuel, payment for telecommunications services, payment for security services, payment of rent, and payment of utilities may be authorized under GLs 14, 15, and 19 provided that they are ordinarily incident and necessary to effectuate the activities authorized by the GLs"
has implications for similar GLs in other programs. GL 14 is unique to the Afghanistan program, but GL 19 is a generally standard NGO-related GL of which equivalents appear in other programs. See General Note on GLs Authorizing Transactions of and Related to Nongovernmental Organizations (NGOs) (System Ed. Note).
With respect to the reference to GL 15, which is also a generally standard GL authorizing exports of agricultural/medical items, OFAC...