The Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued three separate and related general licenses (GLs) relevant to the sanction programmes targeting Iran, Syria, and Venezuela.
Specifically, the three GLs – Iran GL N, Syria GL 21, and Venezuela GL 39 – authorise certain COVID-19-related transactions and activities to aid in the fight against the pandemic.
As explained, the GLs expand upon longstanding and still-in-effect humanitarian exemptions, exceptions, and authorisations already contained in the US sanctions programmes. All three GLs expire on 17 June 2022, subject to any extension subsequently granted by OFAC.
Both US persons and non-US persons whose activities are within US jurisdiction may rely on the expanded authorisations contained in the new GLs, provided the applicable conditions contained therein are met.
Additionally, OFAC FAQ 911 (issued contemporaneously with the GLs) confirms that non-US persons do not risk exposure under US sanctions for engaging in the activities that would be authorised under the new GLs, if engaged in by a US person.
This includes non-US exporters, non-governmental organizations, international organizations, and foreign financial institutions, as well as other non-US persons engaging in certain activities to respond to the COVID-19 pandemic.
