OFAC Issues Humanitarian Exemptions Guidance Amid Calls for More Clarity

The Treasury’s Office of Foreign Assets Control issued an April 16 guidance clarifying available humanitarian trade exemptions for U.S. sanctions regimes that target Iran, Venezuela, North Korea, Syria, Cuba and Ukraine/Russia. The guidance outlines the specific exemptions available for personal protective equipment and stresses that the U.S. will not target legitimate humanitarian trade to sanctioned countries. The guidance comes amid calls from current and former lawmakers and trade experts for more clarity surrounding OFAC humanitarian waivers (see 2004100044, 2004070028 and 2004010019), which has caused confusion among industry (see 2004140027).

The guidance provides a consolidated resource for sanctions-related questions, with links to frequently asked questions, advisories and previous guidance issued for each sanctions regime. OFAC also included brief explanations of the intent of each sanctions regime and said it encourages industry to look through the exemptions and general licenses, which provide a broad range of authorizations for humanitarian exports. OFAC also invited industry to ask questions if they “face sanctions-related challenges,” and said it will continue to respond to license requests during the COVID-19 pandemic. Sanctions-related questions can be directed to (800) 540-6322, (202) 622-2490 or by email to OFAC_Feedback@treasury.gov