On August 25, 2021, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a License (the License) pursuant to OFAC’s Global Terrorism Sanctions Regulations (GTSR or SDGT Sanctions) and Foreign Terrorism Organizations Sanctions Regulations (FTOSR) following a request from the Department of State.  Under Section 1 of the License, the U.S. Government, its employees, grantees, contractors, and others acting on the U.S. Government’s behalf (collectively the Licensees) are authorized to “engage in all transactions necessary and ordinarily incident to the provision of humanitarian assistance in Afghanistan,” which would otherwise be prohibited under GTSR or FTOSR.  As such, the identified licensees may engage in humanitarian-related transactions involving the Taliban, provided such transactions are not otherwise prohibited by any other sanctions law or regulation.  Further, the License permits the transfer of funds for authorized transactions through the U.S. financial system, and does not require blocking or rejecting such transactions.  The License contains other customary restrictions, cautions, and record-keeping requirements required by OFAC. For example, if a Licensee is making use of the License to cover activities of persons acting on the U.S. Government’s behalf, that person must receive a copy of the License.

The license is set to expire on March 1, 2022, though it may be revoked or modified at any time prior to its expiration. The Department of State may request additional licenses as well by submitting a request to the Department of the Treasury no later than 30 days prior to the desired effective start date.

For more information regarding the License and sanctions-implications in Afghanistan, contact our team and see previous posts below.

OFAC Revokes Belarus General License (General License 2G or GL 2G) | International Trade Law (cmtradelaw.com)

OFAC Sanctions Network Attempting to Evade U.S. Sanctions on Venezuela’s Oil Sector | International Trade Law (cmtradelaw.com)