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 U.S. sanctions.
The making of humanitarian donations to recipients in Iran from the United States or by U.S. persons, including the donation of medicine intended to relieve human suffering, are generally exempt from U.S. sanctions on Iran under section 560.210(b) of the Iranian Transactions and Sanctions Regulations, 31 CFR Part 560 (ITSR), provided that such donations are not being made to the Government of Iran or other persons blocked pursuant to section 560.211 of the ITSR, or to any individual or entity listed on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List).
In addition, the United States maintains broad exceptions and authorizations that allow for the commercial sale and export of humanitarian goods, including medicine and medical devices, to Iran or the Government of Iran from the United States or by U.S. persons or U.S.-owned or -controlled foreign entities, subject to certain conditions. U.S. sanctions laws provide similar allowances for sales of humanitarian goods, including medicine and medical devices, to Iran by non-U.S. persons. These exemptions, exceptions, and authorizations generally do not apply to transactions involving persons on OFAC’s SDN List that have been designated in connection with Iran’s support for international terrorism or proliferation of weapons of mass destruction, including the Islamic Revolutionary Guard Corps (IRGC). For humanitarian transactions involving the Central Bank of Iran or the National Iranian Oil Company, which were each designated as a Specially Designated Global Terrorist pursuant to Executive Order (E.O.) 13224 as amended, please see General License 8A issued pursuant to the Global Terrorism Sanctions Regulations (GTSR) and the ITSR, as well as OFAC Frequently Asked Questions (FAQs) 821, 822, and 823.
Furthermore, nongovernmental organizations (NGOs) are authorized under General License E to export or re-export services to or related to Iran in support of certain not-for-profit activities designed to directly benefit the Iranian people, including the provision of donated health-related services and distribution of donated articles such as medicine intended to be used to relieve human suffering, in Iran.
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, General License L issued pursuant to E.O. 13902, and General License 8A issued pursuant to the GTSR and the ITSR, the guidance provided in FAQs 549, 637, 821, 822, 823, 826, 842, 843, and 844, and the guidance provided in the COVID-19 Fact Sheet, “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.
Please note any transfers of funds in support of activities authorized by General License E must be made by the NGOs themselves, and not directly by U.S. individuals, in accordance with the conditions of General License E.