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959. Is support to public hospitals in Afghanistan (e.g., health services, facilities maintenance, and health worker salaries) 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?
Yes. Providing support to public hospitals, such as provision of health services, technical support, and institutional deliveries, as well as payments directly to healthcare workers, that would otherwise be prohibited under the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), or Executive Order (E.O.) 13224, as amended, because of transactions with the Taliban and/or Haqqani Network are authorized under General Licenses (GLs) 14, 15, and 19.
In addition, OFAC has issued Afghanistan-related GL 20 , which, to the extent authorization is required, authorizes all transactions involving Afghanistan...
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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) This FAQ provides some notable examples of transactions that may be "ordinarily incident and necessary to activities authorized by" the relatively standard NGO-related GL (GTSR/FTOSR General License 19). The FAQ has implications for similarly worded GLs (see General Note on GLs Authorizing Transactions of and Related to Nongovernmental Organizations (NGOs) (System Ed. Note)). It is not necessarily obvious from the test of GL 19 that the direct payment of the salaries of health care workers would qualify as "[a]ctivities to support humanitarian projects to meet basic human needs in Afghanistan, including...the provision of health services..." This presumably has implications for sectors apart from health care (confirmed in