NGO-Humanitarian Guidance ​

Date issued: Oct. 17 2014

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TURBOFAC Commentary (586 words)


1) Footnote 1 of this guidance document suggests that previous guidance related to "NGOs" generally is such that, at least as it concerns U.S. person NGOs, OFAC would only consider general licenses referencing NGOs to apply to registered 501(c)(3) tax-exempt status organizations. Given the cross-programmatic, general scope of this guidance, there is no reason to believe that footnote 1 would not reflect OFAC's view of what constitutes an "NGO" in all contexts. In cases involving non-U.S. NGOs subject to the ITSR via 560.215, it is probably safe to presume that OFAC would not consider an entity to be an "NGO" unless it would qualify for 501(c)(3) tax-exempt status if it were a U.S. entity.

2) With respect to point 4, See FAQ 398 and comment thereto for clarification of...