Sanctions Compliance Guidance for the Provision of Humanitarian Assistance to the Palestinian People

The Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury (USDT) has published a new guidance as regards the provision of humanitarian aid to the Palestinian people in Gaza in view of existing sanction regulations and executive orders targeting the Hamas. The guidance, which primarily consists of frequently asked questions (FAQs), is aimed at supporting firms, organizations, and individuals alike in their assessment as to which specific activities may be undertaken to provide humanitarian aid without violating U.S. law. Beforehand, the guidance outlines current restrictions and prohibitions in this context pursuant to 31 CFR Part 594 and 597.
Although most FAQs are rather non-relevant for financial market participants, we would like to point out one question that is likely to be of interest to payment service providers and which reads as follows:
Question: Are NGOs authorized to transfer funds to a designated group or blocked person in connection with an activity authorized by the NGO general licenses?
Answer: No. The NGO general licenses do not authorize funds transfers made with knowledge or reason to know that the intended beneficiary of such transfers is a blocked person, with the exception of payments for taxes, fees, or import duties, or the purchase or receipt of permits, licenses, or public utility services if ordinarily incident and necessary to activities authorized by these authorizations.