PRINT
979. I am a U.S. person. Can I rely on a person sanctioned pursuant to Executive Order (E.O.) 14024 in connection with transactions for official business of an international organization, certain humanitarian-related trade, or the response to the Coronavirus Disease 2019 (COVID-19) pandemic?
Yes, U.S. persons supporting activities undertaken for the official business of certain international organizations or entities, certain humanitarian-related trade, or the response to the COVID-19 pandemic may continue to engage in such activity involving persons sanctioned pursuant to E.O. 14024 through a variety of OFAC authorizations or exemptions, as described below.
Consistent with section 9 of E.O. 14024, transactions for the conduct of the official business of the Federal Government or the United Nations (including its specialized agencies, programs, funds, and related organizations) by employees, grantees, and contractors thereof are exempt from the sanctions prohibitions of E.O. 14024.
Additionally, OFAC has issued...
Click the appropriate link below for access to this file.
Click the appropriate link below for access to this file.
1) This FAQ may have implications for GLs other than those referenced in the FAQ. To the extent that OFAC uses the term "rely on" to in the sense that it is used in the context of remittance GLs [1], i.e. as a diligence-related safe harbor, it is difficult to see why OFAC would take the may "rely on" position in the context of the ag/med and "official business" GLs issued under EO 14024, but not the other ag/med GLs and "official business" provisions found in many other sanctions programs.
[1] See e.g. 560.550:
"(c) The transferring institutions identified in paragraph (a) of this section may rely on the originator of a funds transfer with regard to compliance with paragraph (a) of this section, provided that the transferring institution does not know or have reason to know that the funds transfer...