OFFICE OF FOREIGN ASSETS CONTROL
Fact Sheet: Provision of Humanitarian Assistance and Trade to Combat COVID-19
Date: Updated June 14, 2023
The United States is committed to ensuring that humanitarian assistance continues to reach at- risk populations through legitimate and transparent channels as countries across the globe fight the Coronavirus Disease 2019 (COVID-19). The sanctions programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) generally allow for legitimate humanitarian-related trade, assistance, or activity under existing laws and regulations. OFAC encourages those interested in providing such COVID-19 related assistance to avail themselves of longstanding exemptions, exceptions, and authorizations pertaining to humanitarian assistance and trade available in many U.S. sanctions programs. In the event that individuals, governments, or entities facing sanctions related challenges have questions related to the provision of humanitarian assistance to sanctioned countries, or believe additional authorizations are needed, OFAC stands ready to provide guidance and respond...
Notes:
1) Like many "guidance" documents concerning humanitarian-related goods, this Fact Sheet is less a guidance document and more of a summary of the pre-existing authorities. Put differently, this is more of a primer for those uninitiated with sanctions law than it is something that sheds light on the scope and operation of any particular sanctions provision.
There are, however, a few useful statements in the document.
2) MEDICAL-RELATED SAFE HARBOR IN EO 13902
Sec 1(a)(i) of EO 13902 allows for the sanctioning of non-U.S. persons that "operate in," among others, the "manufacturing" sector of Iran. Sec 1(a)(ii) allows for the sanctioning of non-U.S. persons that "have knowingly engaged...in a significant transaction for the sale, supply, or transfer to or from Iran of significant goods or services used in connection with," among others, the "manufacturing" sector of Iran. Nothing in the EO or the...