No. The Taliban are designated as Specially Designated Global Terrorists (SDGTs) under Executive Order (E.O.) 13224, as amended. The Haqqani Network is designated as an SDGT under E.O. 13224 and a Foreign Terrorist Organization (FTO) under section 219 of the Immigration and Nationality Act (INA). These sanctions do not prohibit U.S. persons from exporting or reexporting goods or services to Afghanistan, provided that the transactions do not involve sanctioned individuals or entities, or property in which a blocked person has an interest unless exempt from regulation or authorized by OFAC.
In addition, OFAC has issued General License No. 14 (GL 14) to facilitate the continuation of humanitarian assistance to, and other activities that support basic human needs in, Afghanistan by nongovernmental organizations (NGOs) and certain international organizations (IOs). GL 14 authorizes the United States Government, NGOs, certain IOs, and their employees, grantees, contractors, or other persons acting on their behalf to provide humanitarian assistance to Afghanistan or other activities that support basic human needs in Afghanistan and that may involve the Taliban, the Haqqani Network, or any entity in which Taliban or the Haqqani Network owns, directly or indirectly, a 50 percent or greater interest, and that would otherwise be prohibited by the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), or Executive Order (E.O.) 13224, as amended, subject to certain conditions.
GL 14 also authorizes U.S. persons to engage in transactions or activities that are ordinarily incident and necessary to authorized humanitarian assistance to or other activities that support basic human needs in Afghanistan. However, GL 14 does not authorize any debit to a blocked account on the books of a U.S. financial institution. In addition, GL 14 does not authorize financial transfers to the Taliban, the Haqqani Network, or any entity in which the Taliban or the Haqqani Network owns, directly or indirectly, a 50 percent or greater interest, other than for the purpose of effecting the payment of taxes, fees, or import duties, or the purchase or receipt of permits, licenses, or public utility services. For purposes of clarity, transfers of funds to or from Afghanistan that are ordinarily incident and necessary to give effect to the activities authorized in GL 14, including clearing and settlement involving banks in Afghanistan, are authorized under GL 14.
Persons authorized under GL 14 include the following entities and their employees, grantees, contractors, or other persons acting on their behalf: (1) the United States Government; (2) NGOs; (3) the United Nations, including its Programmes, Funds, and Other Entities and Bodies, as well as its specialized Agencies and Related Organizations, which includes the World Bank; (4) the International Centre for Settlement of Investment Disputes (ICSID) and the Multilateral Investment Guarantee Agency (MIGA); (5) the African Development Bank Group, the Asian Development Bank, the European Bank for Reconstruction and Development, and the Inter-American Development Bank Group (IDB Group), including any fund entity administered or established by any of the foregoing; (6) the International Committee of the Red Cross and the International Federation of Red Cross and Red Crescent Societies; and (7) the Islamic Development Bank (ISDB).
For an organizational chart of the United Nations, which lists the Programmes, Funds, and Other Entities and Bodies, as well as the Specialized Agencies and Related Organizations covered by GL 14, please see the following page on the United Nations website: https://www.un.org/en/pdfs/un_system_chart.pdf.
For activity outside the scope of GL 14, OFAC may issue specific licenses on a case-by-case basis to authorize certain transactions involving U.S. persons or the U.S. financial system that may otherwise be prohibited by OFAC sanctions, provided those transactions are in the foreign policy interests of the United States.
If individuals, NGOs, IOs, companies, or financial institutions have questions about engaging in or processing transactions related to these authorizations, they may contact OFAC’s Sanctions Compliance and Evaluation Division most efficiently via email at OFAC_Feedback@treasury.gov. Sanctions Compliance and Evaluation may also be reached via phone at (800) 540-6322 or (202) 622-2490.