No. Non-U.S. persons do not risk exposure under U.S. sanctions for engaging in certain activities to respond to the COVID-19 pandemic that would be authorized under Iran GL N-1, Syria GL 21A, or Venezuela GL 39A, as appropriate, if engaged in by a U.S. person. This includes non-U.S. exporters, nongovernmental organizations, international organizations, and foreign financial institutions, as well as other non-U.S. persons engaging in certain activities to respond to the COVID-19 pandemic.
For additional information on humanitarian activities by non-U.S. persons in relation to sanctioned jurisdictions, please see FAQs 844, 884, and 885. For information specific to the provision of humanitarian assistance to the Venezuelan people, please see OFAC’s August 6, 2019 Fact Sheet: Guidance Related to the Provision of Humanitarian Assistance and Support to the Venezuelan People. For more information on other relevant exemptions, exceptions, and authorizations for humanitarian assistance and trade to combat COVID-19 under OFAC’s sanctions program, please see OFAC’s June 10, 2022 Fact Sheet: Provision of Humanitarian Assistance and Trade to Combat COVID-19.
Updated: June 10, 2022