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

Date issued: Jun. 14 2023

Last substantive commentary amendment:
Jun. 14 2024

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TURBOFAC Commentary (1493 words)

Notes:

[6-14-24 update - guidance removed from OFAC's website in light of the concurrent expiration of Iran General License N, Syria General License 21 and Venezuela General License 39. Some of the statements described below remain relevant. The comments below have not been amended since prior to 6-14-24]

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...