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960. Can nongovernmental organizations (NGOs) and international organizations (IOs) make salary support or stipend payments directly to Afghan teachers and healthcare workers?
Yes. Even to the extent doing so would involve transacting with the Taliban and/or Haqqani Network, NGOs can make salary support or stipend payments directly to healthcare workers, such as doctors at public hospitals or healthcare workers at community clinics, under General License (GL) 14 and GL 19. Similarly, even to the extent doing so would involve transacting with the Taliban and/or Haqqani Network, NGOs can make such salary support or stipend payments directly to teachers, including teachers at Afghan public and private schools, under GL 19. Under GL 18, certain IOs can provide such salary support payments directly to healthcare workers and teachers.
In addition, OFAC has issued Afghanistan-related GL 20 , which, to the extent authorization is required, authorizes all transactions...
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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) See comment to FAQ # 959.
3) One implication of the FAQ is that providing "salary support payments directly to healthcare workers and teachers" would or could constitute the "official business" of certain international organizations. See General Note on Exemptions and General Licenses for the “Official Business” of the U.S. Government (and/or United Nations) and Employees, Contractors, or Grantees Thereof.