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955. Are General Licenses (GLs) 17, 18, 19, and 20 consistent with the UN Security Council’s 1988 (Taliban) sanctions regime?
Yes. GLs 14, 15, 16, 17, 18, 19 and 20 help implement recently adopted United Nations Security Council Resolution (UNSCR) 2615 (2021), which authorizes humanitarian assistance and other activities that support basic human needs as those terms are understood by the UN Security Council, as well as the processing and payment of funds, other financial assets or economic resources, and the provision of goods and services necessary to ensure the timely delivery of such assistance or to support such activities. Specifically, UNSCR 2615 was intended to cover activities contemplated in the United Nations’ Transitional Engagement Framework (TEF) for Afghanistan, such as providing life-saving assistance; sustaining essential services; and preserving social investments and community-level systems essential to meeting basic human needs.
These GLs do not relieve any...
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1) This FAQ appears to be a roundabout way of saying that OFAC-administered contain prohibitions that extend far beyond those imposed by the UN, but at the same time they implement the UN sanctions insofar as they do not authorize transactions that would be prohibited under the UN regime. See UNSCR Resolution 2615 (2021), Related Items for the UNSCR resolution referenced in the FAQ. This is a rare situation in that OFAC has issued GLs and explicitly acknowledges that the GLs “help implement” a UNSC resolution. The following sentence can, arguably and in particular with the reference to “intended to cover”, be read for the proposition that items other than those produced by the USG can serve as interpretative aids for the scope of the GLs:
Specifically, UNSCR 2615 (2021) was intended to cover...