Publication of a Fact Sheet on the Provision of Humanitarian Assistance and Trade to Combat COVID-19; Issuance of Iran-related, Venezuela-related, Syria General Licenses and Amended Frequently Asked Questions

The Office of Foreign Assets Control, OFAC, has published a press statement to announce the issuance of three new general licenses to permit certain financial transactions that would otherwise be prohibited pursuant to the Syrian Sanctions Regulations (Statutory Instrument 31 CFR Part 542), the Iranian Transactions and Sanctions Regulations (Statutory Instrument 31 CFR Part 560), and the Venezuela Sanctions Regulations (Statutory Instrument 31 CFR Part 591).
The affected Licenses are the following:
(1) General License GL 21B under the Syrian Sanctions Regulations: It permits financial transactions relating to the „prevention, diagnosis, and treatment of COVID-19“ and financial transactions involving certain blocked parties engaged in such activities.
(2) General License GL N-2 under the Iranian Sanctions Regulations: It permits financial transactions in connection with the export and import of goods and services related to the treatment of COVID-19 and involving the government of Iran. It also permits „certain transactions involving the Central Bank of Iran (CBI) or the National Iranian Oil Company (NIOC)“.
(3) General License GL 39B under the Venezuela Sanctions Regulations: It permits financial transactions „involving the Government of Venezuela that are related to the prevention, diagnosis, or treatment of COVID-19 (including research or clinical studies relating to COVID-19)“ and certain transactions involving listed banks also in connection with the treatment, diagnosis, or study of COVID-19.
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In this context, OFAC has also issued several revised frequently asked questions (FAQs) as quoted below. For the answers, simply click on the provided link. Highly relevant questions are marked in bold.
FAQ 911: Do non-U.S. persons risk exposure to U.S. sanctions for engaging in certain activities to respond to the Coronavirus Disease 2019 (COVID-19) that U.S. persons would be authorized to engage in under Iran General License (GL) N-2, Syria GL 21B, or Venezuela GL 39B?
FAQ 910: What are the due diligence expectations of U.S. financial institutions associated with processing fund transfers or trade finance transactions that are authorized by Iran General License (GL) N-2, Syria GL 21B, and Venezuela GL 39B??
FAQ 909: For the purposes of Venezuela General License (GL) 39B, what are transactions and activities related to the prevention, diagnosis, or treatment of the Coronavirus Disease 2019 (COVID-19)?
FAQ 908: For the purposes of Iran General License (GL) N-2 and Syria GL 21B, what are services related to the prevention, diagnosis, or treatment of the Coronavirus Disease 2019 (COVID-19)? What transactions and activities related to the export or, in the case of Iran GL N-2, import of these services are authorized?
FAQ 907: For the purposes of Iran General License (GL) N-2, what are goods or technology for use in connection with the prevention, diagnosis, or treatment of the Coronavirus Disease 2019 (COVID-19)? What transactions and activities related to the export or reexport of these items are authorized?
FAQ 906: What do Iran General License (GL) N-2, Syria GL 21B, and Venezuela GL 39B authorize with respect to the fight against the Coronavirus Disease 2019 (COVID-19)? How do these GLs differ from OFAC’s existing humanitarian exemptions, exceptions, and authorizations?
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Finally, OFAC has published an updated version of its Fact Sheet: Provision of Humanitarian Assistance and Trade to Combat COVID-19 which is aimed at helping market participants in their efforts to comply with U.S. sanction measures. It primarily outlines (financial) activities that are exempt from the current sanction framework towards Iran, Venezuela, North Korea, Syria, Cuba, and Russia, including the transfer of funds for humanitarian aid, personal remittance, and other trade or service activities. The Fact Sheet thereby summarizes existing licenses, their implications, and corresponding frequently asked questions that the Office has issued in this context.
The latest version includes updates to reflect the above noted newly issued general licenses.