Frequently Asked Questions

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Counter Terrorism Sanctions

812. As a U.S. person, am I prohibited from engaging in transactions involving information or informational materials, including artwork, that are the property or subject to an interest in property of persons designated as Specially Designated Global Terrorists (SDGTs) under or otherwise blocked pursuant to Executive Order 13224, as amended, (E.O. 13224)?

Yes. In general, any transaction or dealing by a U.S. person in any property or interests in property of persons designated as SDGTs under or otherwise blocked pursuant to E.O. 13224 is prohibited. Such property includes artwork and other information and information materials. Certain exemptions available under the International Emergency Economic Powers Act (IEEPA) relating to personal communications, humanitarian donations, information or informational materials, and travel do not apply to transactions with SDGTs or persons otherwise blocked pursuant to E.O. 13224.

For purposes of these prohibitions, U.S. persons include all U.S. citizens and permanent resident aliens regardless of where they are located, all persons and entities within the United States, and all U.S.-incorporated entities and their foreign branches. U.S. persons who engage in prohibited transactions with SDGTs or with persons otherwise blocked pursuant to E.O. 13224 may be subject to civil or criminal penalties.

Non-U.S. persons who engage in prohibited transactions or dealings subject to U.S. jurisdiction with SDGTs or with persons otherwise blocked pursuant to E.O. 13224 may be subject to civil or criminal penalties, and may also risk being sanctioned by OFAC. Foreign financial institutions may also be subject to correspondent and payable through account sanctions if they knowingly facilitate significant transactions for or on behalf of an SDGT.

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813. As a member of the art community, what are my compliance obligations with respect to Executive Order 13224, as amended?

U.S. persons (including galleries, museums, private art collectors, auction companies, and others that conduct or facilitate transactions involving artwork) must ensure that they do not engage in transactions with persons listed as Specially Designated Global Terrorists (SDGTs) on OFAC’s SDN List or with persons otherwise blocked pursuant to E.O. 13224, unless authorized by OFAC. U.S. persons should develop a tailored, risk-based compliance program, which may include sanctions list screening or other appropriate measures. An adequate compliance solution will depend on a variety of factors, including the type of business involved, and there is no single compliance program or solution suitable for every circumstance. For purposes of these requirements, U.S. persons include all U.S. citizens and permanent resident aliens regardless of where they are located, all persons and entities within the United States, and all U.S.-incorporated entities and their foreign branches. U.S. persons who engage in prohibited transactions may be subject to civil or criminal penalties. Non-U.S. persons who engage in prohibited transactions subject to U.S. jurisdiction with SDGTs or persons otherwise blocked pursuant to E.O. 13224 may be subject to civil or criminal penalties, and also risk being sanctioned by OFAC. Foreign financial institutions may be subject to correspondent and payable through account sanctions if they knowingly facilitate significant transactions for or on behalf of a SDGT. The names of, and identifying information for, all individuals and entities included on OFAC’s sanctions lists may be located via OFAC’s free, online search engine at the following URL: http://sanctionssearch.ofac.treas.gov. In addition, OFAC offers text and PDF versions of these lists for manual review and a number of data file versions of its lists that are designed to facilitate automated screening. Depending on the scale, sophistication, and risk profile of your business, you may consider one of the numerous commercially available screening software packages.

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814. I am currently in possession of artwork in which a Specially Designated Global Terrorist (SDGT) has an interest. What should I do?

Once it has been determined that you or your institution is holding or is in possession of artwork that is the property of an SDGT or a person otherwise blocked pursuant to E.O. 13224, or in which such a person has an interest, you or your institution must ensure that access to that artwork is denied to the SDGT or blocked person and that your institution complies with OFAC regulations related to blocked assets, including restrictions on the sale or transfer of the artwork to third parties. Pursuant to 31 CFR section 501.603, blocked property, physical or financial, must be reported to OFAC within 10 business days; U.S. persons must also comply with all other applicable reporting obligations. See FAQs 49 and 50. Questions about whether a transaction should be blocked should be directed to OFAC at 202-622-2490 or ofac_feedback@treasury.gov.

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928. Do U.S. sanctions on the Taliban and the Haqqani Network prohibit the provision of humanitarian assistance to Afghanistan?  

No.  The Taliban is designated as a Specially Designated Global Terrorist (SDGTs) under Executive Order (E.O.) 13224.  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 Licenses (GLs) 14, 15, 16, 17, 18, and 19 under the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), and E.O. 13224, as amended.  For a consolidated list of all relevant General Licenses and FAQs, please see OFAC’s humanitarian Fact Sheet, “Provision of Humanitarian Assistance to Afghanistan and Support for the Afghan People,” which provides an overview of the relevant authorizations and guidance related to U.S. sanctions on the Taliban and the Haqqani Network. 

The GLs mentioned above do not authorize any debit to a blocked account on the books of a U.S. financial institution.  In addition, these GLs do 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 effectuating the payment of taxes, fees, or import duties, or the purchase or receipt of permits, licenses, or public utility services.  

For activity outside the scope of these GLs, 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, nongovernmental organizations, international organizations, 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.   OFAC prioritizes license applications, compliance questions and other requests that are related to humanitarian support.
 

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929. For the purposes of General License (GL) 14, what is "humanitarian assistance to Afghanistan" or "other activities that support basic human needs in Afghanistan"?

For the purposes of GL 14, humanitarian assistance includes the provision of relief services related to natural and man-made disasters, the provision of healthcare and health-related services, protection and assistance for vulnerable or displaced populations (including women, individuals with disabilities, the elderly, survivors of violence, those incarcerated or detained, and the drug dependent), operation of orphanages, the distribution of articles (such as food, clothing, and medicine) intended to be used to relieve human suffering in Afghanistan, and training or other services related to any of the foregoing activities.  Other activities that support basic human needs include activities to support non-commercial development projects in Afghanistan that primarily benefit poor or at-risk populations or otherwise relieve human suffering, including activities related to shelter and settlement assistance, food security, livelihoods support, water, sanitation, health, hygiene, and COVID-19-related assistance, among others, and training or other services related to any of the foregoing activities.  However, in all cases, authorized humanitarian assistance and other activities that support basic human needs in Afghanistan must not entail 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, and import duties, or the purchase or receipt of permits, licenses, or public utility services described in GL 14 and FAQ 928.

For more information on relevant authorizations and guidance for providing humanitarian assistance to Afghanistan, please see OFAC’s humanitarian Fact Sheet, “Provision of Humanitarian Assistance to Afghanistan and Support for the Afghan People,” which provides an overview of the relevant authorizations and guidance related to U.S. sanctions on the Taliban and the Haqqani Network. 

If individuals, nongovernmental organizations, international organizations, companies, 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.

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930. Do U.S. sanctions on the Taliban and the Haqqani Network prohibit the exportation or reexportation of agricultural commodities, medicine, and medical devices to Afghanistan? 

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. 15 (GL 15) under the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), and E.O. 13224, as amended.  GL 15 authorizes U.S. persons to engage in all transactions that are ordinarily incident and necessary to the exportation or reexportation of agricultural commodities, medicine, medical devices, replacement parts, and components for medical devices, or software updates for medical devices to Afghanistan, as those terms are defined in GL 15, as well as to persons in third countries purchasing specifically for resale to 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, subject to certain conditions.  

GL 15 also authorizes U.S. persons to engage in transactions or activities that are ordinarily incident and necessary to authorized export or reexports, including the processing of financial transactions and related clearing and settlement involving banks in Afghanistan.  However, GL 15 does not authorize any debit to a blocked account on the books of a U.S. financial institution.  In addition, GL 15 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 15, including clearing and settlement involving banks in Afghanistan, are authorized under GL 15. 

Where not covered by GL 15, OFAC may also issue specific licenses 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, entities, companies, 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.
 

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931. Do non-U.S. persons risk exposure to U.S. sanctions for engaging in transactions that U.S. persons would be authorized to engage in under General Licenses (GLs) 14, 15, 16, 17, 18, or 19?

No.  Non-U.S. persons may engage in or facilitate transactions that would be authorized for U.S. persons under GLs 14, 15, 16, 17, 18, or 19 without exposure to sanctions 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. 

For example, activity that would be authorized by GLs 14, 15, 16, 17, 18, or 19 if engaged in by a U.S. person would not be considered “significant” for the purposes of a secondary sanctions determination under E.O. 13224, as amended.  Accordingly, foreign financial institutions do not risk exposure to correspondent and payable-through account sanctions under E.O. 13224, as amended, if they knowingly conduct or facilitate a significant transaction on behalf of persons blocked under E.O. 13224, as amended, that would be authorized under GLs 14, 15, 16, 17, 18, or 19 if engaged in by a U.S. person. 

For more information on relevant authorizations and guidance for providing humanitarian assistance to Afghanistan, please see OFAC’s humanitarian Fact Sheet, “Provision of Humanitarian Assistance to Afghanistan and Support for the Afghan People,” which provides an overview of the relevant authorizations and guidance related to U.S. sanctions on the Taliban and the Haqqani Network. 

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.

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949. Do sanctions administered by the Office of Foreign Assets Control (OFAC) on the Taliban and the Haqqani Network prohibit the sending of personal remittances to Afghanistan?

No.  The Taliban is designated as a Specially Designated Global Terrorist (SDGT) under Executive Order (E.O.) 13224, as amended.  The Haqqani Network is designated as an SDGT under E.O. 13224, as amended, 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 (including noncommercial, personal remittances) 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.  For example, U.S. sanctions do not prohibit the hand-carrying of noncommercial, personal remittances to an individual in Afghanistan or ordinarily resident in Afghanistan, other than a blocked individual.

In addition, OFAC has issued General License (GL) 16 to facilitate the transfer of noncommercial, personal remittances to individuals in Afghanistan.  GL 16 authorizes U.S. persons to engage in transactions that are ordinarily incident and necessary to the transfer of noncommercial, personal remittances, including through Afghan depository institutions, and that may 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, that are prohibited by the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), or E.O. 13224, as amended.

However, GL 16 does not authorize any debit to a blocked account of 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, on the books of a U.S. financial institution.  In addition, GL 16 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, individually or in the aggregate, a 50 percent or greater interest, other than for the purpose of effecting the payment of reasonable and customary taxes, fees, or other duties.  Transactions that are ordinarily incident and necessary to give effect to the activities authorized in GL 16, including clearing, settlement, and transfers through, to, or otherwise involving privately-owned and state-owned Afghan depository institutions, are authorized pursuant to GL 16. 

For activity outside the scope of GL 16, 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.
 

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950. For purposes of Afghanistan General License (GL) 18, “Official Activities of Certain International Organizations and Other International Entities,” what organizations are included within the United Nations’ “Programmes, Funds, and Other Entities and Bodies, as well as its Specialized Agencies and Related Organizations”? 

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 18 , including the World Bank, please see this page on the United Nations website. 

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951. Is Afghanistan subject to comprehensive sanctions?

No.  In contrast to sanctions programs administered and enforced by OFAC with regard to North Korea, Cuba, Iran, Syria, and the Crimea region of Ukraine, there are no comprehensive sanctions on Afghanistan.  Therefore, there are no OFAC-administered sanctions that prohibit the export or reexport of goods or services to Afghanistan, moving or sending money into and out of Afghanistan, or activities in Afghanistan, provided that such transactions or activities do not involve sanctioned individuals, entities, or property in which sanctioned individuals and entities have an interest.

Certain Afghanistan-related individuals and entities are included on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List), most notably the Taliban and the Haqqani Network.  The Taliban are designated as a Specially Designated Global Terrorist (SDGT) under Executive Order (E.O.) 13224.  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.  Transactions or activities by U.S. persons that involve these entities are generally prohibited.  

In addition, OFAC has issued GLs 14, 15, 16, 17, 18, and 19 under the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), and E.O. 13224, as amended.  For a consolidated list of all relevant General Licenses and FAQs, please see OFAC’s humanitarian Fact Sheet , “Provision of Humanitarian Assistance to Afghanistan and Support for the Afghan People,” that provides an overview of the relevant authorizations and guidance related to U.S. sanctions on the Taliban and the Haqqani Network. 

In addition to the Taliban and the Haqqani Network, there are other Afghanistan-related individuals and entities on the SDN List, including certain individual members of the Taliban or Haqqani Network explicitly designated as SDGTs, and other individuals and entities designated under other sanctions programs, such as Counter Narcotics Trafficking Sanctions.  Transactions or activities that involve these sanctioned persons or property in which such persons have an interest are generally prohibited, unless exempt from regulation or authorized by OFAC.  GLs 14, 15, 16, 17, 18, and 19 do not authorize transactions or activities that involve these other sanctioned persons or property in which such persons have an interest.
 

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952. When operating in Afghanistan, how can I tell who is a member of the Taliban or the Haqqani Network, which are designated are Specially Designated Global Terrorists (SDGT) under U.S. counterterrorism sanctions?

A number of members of the Taliban and/or the Haqqani Network are explicitly included on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List).  Persons operating in Afghanistan can use OFAC’s SDN List Search Tool to identify such members of the Taliban or the Haqqani Networks explicitly included on the SDN List, as well as other individuals or entities explicitly subject to U.S. sanctions.  For more information on using OFAC’s SDN List Search Tool and assessing OFAC Name Matches, please see OFAC FAQs 5, 82, 246-253, 287, 369, 467, and 892.  Counterterrorism General Licenses (GLs) 14, 15, 16, 17, 18, and 19  do not authorize transactions or activities that involve these sanctioned persons or property in which such persons have an interest.

OFAC would encourage any person operating in Afghanistan to use all information at their disposal when assessing their risk for sanctions exposure.  Supplementing internal due diligence information with an array of open-source material can be an effective compliance practice to aid in identifying risky counterparties involved in any in-country activity.  For more information on OFAC due diligence expectations and compliance programs, please see FAQs 25, 27-31 and A Framework for OFAC Compliance Commitments .
 

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953. Do U.S. sanctions on the Taliban and the Haqqani Network prohibit moving or sending money into or out of Afghanistan?  Do U.S. sanctions prohibit or require a particular method of payment for moving or sending money into or out of Afghanistan?

No.  U.S. sanctions on the Taliban and the Haqqani Network do not prohibit the movement of funds into or out of Afghanistan, provided that the transactions do not involve blocked individuals or entities, or property in which a blocked person has an interest.  

In addition, OFAC has issued General Licenses (GLs) 14, 15, 16, 17, 18, and 19 under the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), and E.O. 13224, as amended.  For a consolidated list of all relevant General Licenses and FAQs, please see OFAC’s humanitarian Fact Sheet , “Provision of Humanitarian Assistance to Afghanistan and Support for the Afghan People,” that provides an overview of the relevant authorizations and guidance related to U.S. sanctions on the Taliban and the Haqqani Network. 

U.S. sanctions on the Taliban and the Haqqani Network do not prohibit — and GLs 14, 15, 16, 17, 18, and 19 do not require — any particular method for moving or sending money into or out of Afghanistan.  When selecting a method of payment — including electronic transfer or hand carrying of funds — OFAC urges due diligence tailored to the particular sanctions risks to ensure that payments do not involve individuals or entities identified on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List) or whose property and interests in property are otherwise blocked, unless exempt from regulation or authorized by OFAC.  For more information on OFAC due diligence expectations and compliance programs, please see FAQs 25, 27-31 and A Framework for OFAC Compliance Commitments.
 

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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?

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.
 

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955. Are General Licenses (GLs) 17, 18, and 19 consistent with the UN Security Council’s 1988 (Taliban) sanctions regime?

These GLs authorize certain activities that would otherwise be prohibited under U.S. sanctions on the Taliban and the Haqqani Network.  Given the scope of these domestic sanctions, these GLs authorize many activities that do not implicate the UN Security Council ‘s 1988 (Taliban) sanctions regime.  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.

GLs 14, 15, 16, 17, 18, and 19 also help implement recently adopted UNSCR 2615 (2021),  which authorizes humanitarian assistance and other activities that support basic human needs as those terms are understood by the UN Security Council, as well as the processing and payment of funds, other financial assets or economic resources, and the provision of goods and services necessary to ensure the timely delivery of such assistance or to support such activities.  Specifically, UNSCR 2615 (2021) was intended to cover activities contemplated in the United Nations’ Transitional Engagement Framework (TEF) for Afghanistan, such as providing life-saving assistance; sustaining essential services; and preserving social investments and community-level systems essential to meeting basic human needs.

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