991. Why did the Department of the Treasury issue Afghanistan-related General License (GL) 20, “Authorizing Transactions Involving Afghanistan or Governing Institutions in Afghanistan”?
The U.S. government recognizes that Afghanistan is facing a widespread humanitarian and economic crisis. Treasury issued Afghanistan-related GL 20 to ensure that U.S. sanctions do not stand in the way of transactions and activities that support basic human needs of the people in Afghanistan. GL 20 authorizes, to the extent authorization is required, activities necessary to support these needs, including, as established in the United Nations Transitional Engagement Framework (TEF) for Afghanistan, activities necessary to sustain essential social services such as health and education, preserve essential community systems, and promote livelihoods and social cohesion. This GL helps provide clarity to financial institutions, nongovernmental organizations, international organizations, and private sector entities that they can facilitate the broad range of activities needed to mitigate further...
1) Note the key phrase "to the extent authorization is required…" This indicates that OFAC, consistent with all previous guidance on the Taliban since it assumed de facto control over the governing institutions of Afghanistan, does not necessarily have an "interest" in all such transactions (but, depending on the facts, may). GL 20 removes the need for the fact-intensive inquiry that would otherwise need to accompany transactions involving Government of Afghanistan transactions that are not otherwise authorized by one of the GLs issued prior to GL 20. Refer generally to Temporary Note Concerning the Status of the Unrecognized Government of Afghanistan Under the GTSR.