As one example, if a non-governmental organization is providing support directly to Afghan hospitals or healthcare workers but needs to sign a memorandum of understanding that involves the Taliban in order to provide such support directly to the Afghan people, this engagement would be authorized under General Licenses (GLs) 14 and 19.
Other examples of engagement with the Taliban and the Haqqani Network that are authorized under GLs 14 and 19 if they are ordinarily incident and necessary to activities authorized by these GLs include: (i) general coordination on delivery and provision of humanitarian aid or shipments; (ii) administrative issues involving importation of goods; (iii) attendance at donor coordination meetings; (iv) sharing descriptions of projects; (v) coordination with regard to travel or project locations; (vi) participation in technical working groups; and (vii) sharing of office space.
In addition, payments of taxes, fees, or import duties to, or the purchase or receipt of permits, licenses, or public utility services from, 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, are authorized under GLs 14 and 19, if ordinarily incident and necessary to activities authorized by the GLs.
In addition, OFAC has issued Afghanistan-related GL 20 , which, to the extent authorization is required, authorizes all transactions involving Afghanistan or governing institutions in Afghanistan prohibited under 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 limited conditions set forth in GL 20 paragraph (b). GL 20 therefore also covers transactions involving the Taliban or the Haqqani Network that are authorized under GLs 14 and 19.
As noted in FAQ 996, the authorization in Afghanistan-related GL 20 may overlap with the authorizations in Afghanistan-related GLs 14 and 19. Where appropriate, U.S. persons may rely on the broader authorization in GL 20 instead of the authorizations in GLs 14 and 19.
Date Updated: February 25, 2022