Earlier this month, the Office of Foreign Assets Control (OFAC) issued an FAQ to assure US persons that “there are a number of ways to provide humanitarian goods or assistance to the Iranian people in response to the COVID-19 outbreak in Iran, consistent with US sanctions.”
- humanitarian donations including medicine from the US or US persons.
- commercial sale and export of medicine and medical devices by US persons, US owned or controlled entities and non-US persons
However donations may not be made to the Iranian government or specially designated nationals (SDNs), and sales may not be made to SDNs, which may still cause compliance difficulties.
Finally, NGOs are authorised under General License E to export services to Iran to benefit the people. Any transfer of funds or activities under this GL must be made by the NGOs themselves, not US individuals.
Persons interested in providing humanitarian assistance to Iran related to the COVID-19 outbreak should review sections 560.210(b), 560.530, 560.532, and 560.533 and General License E of the ITSR and General License 8 issued pursuant to the GTSR and the ITSR, the guidance provided in FAQs 549, 637, 821, 822, 823, and 826, and the guidance provided in “Guidance on the Sale of Food, Agricultural Commodities, Medicine, and Medical Devices by Non-U.S. Persons to Iran” and “Clarifying Guidance on Humanitarian Assistance and Related Exports to the Iranian People.” Other types of humanitarian activities or exports by U.S. persons may be authorized pursuant to a specific license from OFAC.