Guidance for the Provision of Humanitarian-Related Assistance and Critical Commodities to the Yemeni People - Q # 2

Date issued: Feb. 16 2024

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TURBOFAC Commentary (165 words)

Notes:

1) The relevant NGO GL (594.520) authorizes specified enumerated activities "designed to directly benefit the civilian population," including "Activities to support humanitarian projects to meet basic human needs, including disaster, drought, or flood relief; food, nutrition, or medicine distribution; the provision of health services; assistance for vulnerable or displaced populations, including individuals with disabilities and the elderly; and environmental programs." Here, OFAC appears to be interpreting "humanitarian projects to meet basic human needs" as covering general infrastructure projects. Query whether this could cover, e.g., roads. Refer generally to General Note on GLs Authorizing Transactions of and Related to Nongovernmental Organizations (NGOs) (System Ed. Note).

2) See comment 4 to 594.520 concerning the statement that the GL "does not authorize funds transfers to blocked individuals or entities, outside of taxes, fees, or import duties, or the...