Fact Sheet: Provision of Humanitarian Assistance and Trade to Combat COVID-19

Date issued: Jun. 16 2023

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TURBOFAC Commentary (1452 words)

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...