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957. Can non-U.S. companies ship food and agricultural products to Afghanistan? Can banks process these transactions?
Yes. Both U.S. and non-U.S. companies can ship food to Afghanistan, and banks can process financial transfers and other transactions associated with food shipments to Afghanistan.
As described in FAQ 930, U.S. sanctions do not specifically prohibit the exportation or reexportation of agricultural commodities, medicine, and medical devices to Afghanistan.
OFAC has also issued Afghanistan-related General License (GL) 15, which authorizes U.S. persons to engage in all transactions that are ordinarily incident and necessary to the exportation or reexportation of agricultural commodities, medicine, medical devices, replacement parts, and components for medical devices, or software updates for medical devices to Afghanistan, as those terms are defined in GL 15, as well as to persons in third countries purchasing specifically for resale to Afghanistan, and that may involve the Taliban, the...
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1) FAQ Amended on 2-25-2022 to add non-substantive references to GTSR/FTOSR General License 20, and note overlap with pre-existing GLs.
2) Read in conjunction with FAQ # 930. The primary purpose of this FAQ appears to be to clarify that "GL 15 also authorizes U.S. persons to engage in transactions or activities that are ordinarily incident and necessary to authorized exports or reexports, including the processing of financial transactions and related clearing and settlement involving privately-owned and state-owned banks in Afghanistan" (emphasis added).
FAQ # 930, by contrast, made reference only to "the processing of financial transactions and related clearing and settlement involving banks in Afghanistan."
The specification is significant, because it implies that "state-owned banks in Afghanistan" are not necessarily blocked persons by virtue of their association with or...