Frequently Asked Questions

954. Are purchases of fuel, payment for telecommunications services, payment for security services, payment of rent, and payment of utilities by nongovernmental organizations (NGOs) considered ordinarily incident and necessary to authorized activities under General Licenses (GLs) 14, 15, and 19?

Answer

The purchases of fuel, payment for telecommunications services, payment for security services, payment of rent, and payment of utilities may be authorized under GLs 14, 15, and 19 provided that they are ordinarily incident and necessary to effectuate the activities authorized by the GLs.  As with all OFAC GLs, GLs 14, 15, and 19 are “self-executing,” meaning that persons who determine that such activities are ordinarily incident and necessary to their authorized activity within the scope of the GL may proceed without further assurance from OFAC.  

In addition, OFAC has issued GL 17 to authorize all transactions that are for the conduct of the official business of the United States Government by employees, grantees, or contractors and that involve the Taliban or the Haqqani Network, or any entity in which the Taliban or the Haqqani Network owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest.  OFAC also issued GL 18 to authorize all transactions that are for the conduct of official business by employees, grantees, or contractors of certain international organizations (IOs) and that involve the Taliban or the Haqqani Network, or any entity in which the Taliban or the Haqqani Network owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest.

In all cases, authorized transactions and activities must comply with the terms and conditions set forth in GLs 14, 15, 17, 18, and 19.  Notably, these GLs explicitly do not authorize financial transfers to the Taliban or the Haqqani Network, 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 related to the activities specified.  In addition, these GLs do not relieve any person from compliance with other U.S. federal laws or requirements of other federal agencies, or from applicable international obligations.

If individuals, entities, international organizations, or financial institutions have questions about engaging in or processing transactions related to these authorizations, they can 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.  OFAC prioritizes license applications, compliance questions, and other requests that are related to humanitarian support.
 

Date Released
December 22, 2021