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.”

These include:

  • 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.