Frequently Asked Questions

No.  The United States has not lifted sanctions on the Taliban and the Haqqani Network.  The Taliban remains designated as a Specially Designated Global Terrorist (SDGT) under Executive Order (E.O.) 13224.  The Haqqani Network remains designated as an SDGT under E.O. 13224 and a Foreign Terrorist Organization (FTO) under section 219 of the Immigration and Nationality Act (INA).  Transactions involving the Taliban or the Haqqani Network outside the scope of GLs 14, 15, 16, 17, 18, 19 and 20  remain prohibited.

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To the extent authorization is required, Afghanistan-related GL 20  authorizes all transactions involving Afghanistan or governing institutions in Afghanistan 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 limited conditions set forth in GL 20 paragraph (b).  

Therefore, the authorization in Afghanistan-related GL 20 may overlap with the authorizations in Afghanistan-related 1415161718 and 19.  Where appropriate, U.S. persons may rely on the broader authorization in GL 20 instead of the authorizations in GLs 14, 15, 16, 17, 18, and 19.  As with all OFAC GLs, GLs 14, 15, 16, 17, 18, 19 and 20 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.

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Yes.  To the extent authorization is required, GL 20  authorizes financial transfers to or involving all governing institutions in Afghanistan — including but not limited to the DAB, Ministry of Education, Ministry of Energy and Water, Ministry of Finance, Ministry of Agriculture, Irrigation, and Livestock, and Ministry of Public Health — or to or involving state-owned or -controlled companies and enterprises in Afghanistan, including Da Afghanistan Breshna Sherkat (DABS), provided there are no financial transfers to the Taliban, the Haqqani Network, 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, or any blocked individual who is in a leadership role of a governing institution in Afghanistan, 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, provided that such payments do not relate to luxury items or services.  GL 20 also authorizes receipt of payment from such governing institutions and state-owned or -controlled companies and enterprises in Afghanistan.

OFAC does not view financial transfers to governing institutions in Afghanistan or state-owned or -controlled companies and enterprises in Afghanistan as financial transfers to the Taliban, the Haqqani Network, 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, or any blocked individual who is in a leadership role of a governing institution in Afghanistan.  

Nothing in GL 20 affects the property or interests in property of Da Afghanistan Bank that are protectively blocked pursuant to Executive Order (E.O.) 14064 of February 11, 2022, “Protecting Certain Property of Da Afghanistan Bank for the Benefit of the People of Afghanistan.”
 

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For purposes of GL 20 , luxury items and services are those items and services that are not linked to activities that support basic human needs as defined with reference to United Nations Security Council Resolution 2615 (2021), for instance:  yachts, furs, designer clothing, and certain entertainment activities.  Luxury items  and services would not include, for example, phones, computers, or other similar items commonly used in connection with personal communication, education, activity by international organizations and non-governmental organizations, and other activity that supports basic human needs in Afghanistan.

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Generally speaking, when a designated individual has a leadership role in a governing institution, the governing institution itself is not considered blocked.  Accordingly, engaging in a routine interaction with an agency in which a blocked individual is an official, but that does not involve the blocked individual in question, is not prohibited. 

In this case, Afghanistan-related General License (GL) 20  authorizes all transactions involving Afghanistan or governing institutions in Afghanistan that would otherwise be prohibited by OFAC-administered sanctions on the Taliban or the Haqqani Network, subject to certain conditions.  GL 20 also authorizes the payment of taxes, fees, or import duties, or the purchase of permits, licensing, or public utility services to blocked individuals that are in leadership roles of governing institutions in Afghanistan, provided that such payments do not relate to luxury items  or services.

As an example, if an international organization (IO), nongovernmental organization (NGO), or company needs to make a customs payment to a governing institution in Afghanistan led by a blocked individual, that is authorized.  Similarly, if an IO, NGO, or company is signing a contract to provide services to or on behalf of that governing institution, and the blocked individual appointed to lead that governing institution needs to sign the contract in their official capacity on behalf of the governing institution, that is authorized.  However, if the blocked individual requests that funds be provided directly to them, 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 or financial transfers, that would not be authorized by GL 20.

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Transactions that are generally authorized by GL 20  to the extent authorization is required include:  

  • Commercial transactions involving Afghanistan, including imports from Afghanistan, exports to Afghanistan, and commercial transactions within or involving the geographical territory of Afghanistan; 
  • Dealings with all governing ministries and institutions in Afghanistan—including the Ministry of Education, Ministry of Energy and Water, Ministry of Finance, Ministry of Agriculture, Irrigation, and Livestock, Ministry of Public Health, Ministry of Economy, Ministry of the Interior, and Ministry of Refugees and Repatriations, and the Central Bank of Afghanistan (DAB);
  • Dealings with state-owned or -controlled companies and enterprises in Afghanistan, including the electrical utility Da Afghanistan Breshna Sherkat (DABS); 
  • Payment of taxes, fees, or import duties, or the purchase or receipt of permits, licenses, or public utility services, provided that such payments do not relate to luxury items or services;
  • Financial institutions’ processing of transactions to, from, or transiting Afghanistan, including clearing, settlement, and transfers through, to, or otherwise involving privately owned and state-owned Afghan banks;
  • Financial and professional services related to economic activity in Afghanistan;
  • Activities related to infrastructure maintenance or development in Afghanistan, including water, sanitation, energy, electricity, and public utilities;
  • Activities related to the development, maintenance, and operation of civilian transportation in Afghanistan, including safety and maintenance operations for civilian transportation in Afghanistan, including air traffic services, air navigation services, other transactions ordinarily incident and necessary to operations or use of airports, ground and landside operations, and rail or road construction or maintenance;
  • Transactions with respect to the receipt and transmission of telecommunications, mail, or parcels involving Afghanistan; 
  • Importation from and exportation to Afghanistan of any information or informational materials;
  • Transactions ordinarily incident to travel to or from Afghanistan; 
  • Transactions that are also authorized under Afghanistan-related GLs 1415161718 and 19 (for more information, see FAQs 928, 929, 930, 931, 949, 951, 953, 954, 957, 958, 959, 960, 961, 962, 963, and 996); and
  • Incidental contact with the Taliban or the Haqqani Network or any blocked individual who is currently in a leadership role in a governing institution in Afghanistan in connection with any of the authorized activities outlined above. 

Nothing in GL 20 relieves any person from compliance with any other federal laws or requirements of other federal agencies, including the International Traffic in Arms Regulations (ITAR) administered by the Department of State and the Export Administration Regulations (EAR) administered by the Department of Commerce, or from applicable international obligations.

GL 20 does not authorize financial transfers to the Taliban, the Haqqani Network, 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, or to any blocked individual who is in a leadership role of a governing institution in Afghanistan, 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 or financial transfers, provided that such payments do not relate to luxury items or services.  GL 20 also does not authorize transfers of luxury items or services to the Taliban, the Haqqani Network, 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, or any blocked individual who is in a leadership role of a governing institution in Afghanistan.

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The U.S. government recognizes that Afghanistan is facing a widespread humanitarian and economic crisis.  Treasury issued Afghanistan-related GL 20  to ensure that U.S. sanctions do not stand in the way of transactions and activities that support basic human needs of the people in Afghanistan.  GL 20 authorizes, to the extent authorization is required, activities necessary to support these needs, including, as established in the United Nations Transitional Engagement Framework (TEF) for Afghanistan, activities necessary to sustain essential social services such as health and education, preserve essential community systems, and promote livelihoods and social cohesion.  This GL helps provide clarity to financial institutions, nongovernmental organizations, international organizations, and private sector entities that they can facilitate the broad range of activities needed to mitigate further worsening of Afghanistan’s economic and humanitarian crisis.  This includes commercial activities in or involving Afghanistan.  For other specific examples of the kinds of activities authorized by General License 20, please see FAQ 992

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