Iran General License (No. E) - Authorizing Certain Services in Support of Nongovernmental Organizations’ Activities in Iran

Date issued: Oct. 10 2013

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TURBOFAC Commentary (506 words)


1) GL builds on the licensing policy concerning NGO activity at 560.545.

2) The term "NGO" is not a legally defined term in U.S. sanctions regulations (it may not be a legally defined term in any federal law), and there is a range of different definitions of the term. NGO-Humanitarian Guidance (2014) suggests that, at least as it concerns U.S. person NGOs, OFAC would only consider licenses to apply to registered 501(c)(3) tax exempt status organizations. In other guidance, OFAC does not define "NGO" or otherwise make the registered 501(c)(3) requirement explicit. Considering that this GL applies to both U.S. entities as well as services in support of non-U.S. entities subject to the ITSR via 560.215, it is probably safe to presume that OFAC would...