OFAC authorized transactions involving the Taliban or the Haqqani Network by the U.S. government and certain non-governmental and international organizations for the exportation or reexportation of agricultural commodities, medicine and medical devices that would be otherwise prohibited by the Global Terrorism Sanctions Regulations, the Foreign Terrorist Organizations Sanctions Regulations or Executive Order 13224.
In General License ("GL") No. 14 and GL No. 15, OFAC specified that:
- payments to the Taliban, Haqqani Network and related entities are authorized only to the extent such financial transfers are for the purposes of paying "taxes, fees, or import duties, or the purchase or receipt of permits, licenses, or public utility services"; and
- the authorizations do not extend to "[a]ny debit to an account on the books of a U.S. financial institution of any blocked person."
In four new FAQs, OFAC clarified:
- that the purpose of GL Nos. 14 and 15 is to facilitate the provision of (i) humanitarian assistance to Afghanistan (FAQ 928) and (ii) the exportation or reexportation of agricultural commodities, medicine and medical devices to Afghanistan (FAQ 930);
- the types of humanitarian assistance covered by GL No. 14 (FAQ 929); and
- that non-U.S. persons do not risk exposure to U.S. sanctions when engaging in transactions authorized by GL Nos. 14 and 15 (FAQ 931).
Primary Sources
- Treasury Press Release: Treasury Issues General Licenses and Guidance to Facilitate Humanitarian Assistance in Afghanistan
- OFAC General License No. 14: Authorizing Humanitarian Activities in Afghanistan
- OFAC General License No. 15: Transactions Related to the Exportation or Reexportation of Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates in Afghanistan
- OFAC FAQ: Counter Terrorism Sanctions - 928
- OFAC FAQ: Counter Terrorism Sanctions - 929
- OFAC FAQ: Counter Terrorism Sanctions - 930
- OFAC FAQ: Counter Terrorism Sanctions - 931
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.