In order to further aid the global fight against COVID-19, OFAC has issued time-limited general licenses, Iran GL N, Syria GL 21, and Venezuela GL 39 (together, the COVID-19-related GLs), to provide broad authorizations for certain COVID-19-related transactions and activities. The new general licenses expand upon longstanding humanitarian exemptions, exceptions, and authorizations in OFAC sanctions programs, which remain in effect (see OFAC’s April 16, 2020 Fact Sheet on the Provision of Humanitarian Assistance and Trade to Combat COVID-19) to cover additional COVID 19-related transactions and activities. For example, Iran GL N expands authorizations under the Iran sanctions program to cover certain items that previously would have required a specific license for exportation or reexportation to Iran, such as certain COVID-19 testing or vaccine manufacturing equipment. Both U.S. persons and non-U.S. persons whose activities are within U.S. jurisdiction — including exporters, nongovernmental organizations, international organizations, and financial institutions — may rely upon the authorizations in these COVID-19-related GLs provided they meet the applicable conditions. All three GLs expire on June 17, 2022.
The COVID-19-related GLs provide authorization that is independent of OFAC’s other humanitarian-related authorizations. Accordingly, conditions and limitations included in other humanitarian-related authorizations do not apply to transactions and activities conducted pursuant to the COVID-19-related GLs, unless explicitly incorporated therein. For example, for sales to Iran of agricultural commodities, food, medicine, and medical devices pursuant to the general license in 31 C.F.R. § 560.530, payment terms and financing must be limited to and consistent with those authorized by 31 C.F.R. § 560.532. However, because Iran GL N does not incorporate similar limitations on payment terms, COVID-19-related exports and reexports to Iran authorized by Iran GL N are not subject to the payment terms in 31 C.F.R. § 560.532.
Prior to the expiration of the COVID-19-related GLs, OFAC may issue additional guidance, as appropriate. OFAC’s longstanding humanitarian exemptions, exceptions and authorizations in each of these sanctions programs will not be impacted by the expiration of these GLs. For transactions not otherwise authorized or exempt, OFAC considers license requests on a case-by-case basis and prioritizes applications, compliance questions, and other requests related to humanitarian support for people in areas subject to comprehensive sanctions.