Yes. Support to municipal water systems by NGOs for projects that directly benefit the Afghan people or otherwise relieve human suffering that would otherwise be 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, because of transactions with the Taliban and/or Haqqani Network would be covered by General Licenses (GLs) 14 and 19. GL 18 authorizes all transactions and activities with the Taliban and/or Haqqani Network otherwise prohibited under the GTSR or FTOSR that are for the conduct of the official business of certain IOs. Thus, if support to municipal water systems is part of these IOs’ official business, then it would not be prohibited.
For example, this could include providing technical support to a project related to clean drinking water or making improvements to water systems for the benefit of the Afghan people.
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 GTSR, the FTOSR, or E.O. 13224, as amended, subject to limited conditions set forth in GL 20 paragraph (b). GL 20 therefore also covers support to municipal water systems by NGOs, IOs, or other persons.
As noted in FAQ 996, the authorization in Afghanistan-related GL 20 may overlap with the authorizations in Afghanistan-related GLs 14, 18, and 19. Where appropriate, U.S. persons may rely on the broader authorization in GL 20 instead of the authorizations in GLs 14, 18, and 19.
Date Updated: February 25, 2022