U.S. Department of the Treasury

No.  Non-U.S. persons do not risk exposure under U.S. sanctions for engaging in certain activities to respond to the COVID-19 pandemic that would be authorized under Iran GL N-1, Syria GL 21A, or Venezuela GL 39A, as appropriate, if engaged in by a U.S. person.  This includes non-U.S. exporters, nongovernmental organizations, international organizations, and foreign financial institutions, as well as other non-U.S. persons engaging in certain activities to respond to the COVID-19 pandemic.

For additional information on humanitarian activities by non-U.S. persons in relation to sanctioned jurisdictions, please see FAQs 844, 884, and 885.  For information specific to the provision of humanitarian assistance to the Venezuelan people, please see OFAC’s August 6, 2019 Fact Sheet: Guidance Related to the Provision of Humanitarian Assistance and Support to the Venezuelan People.  For more information on other relevant exemptions, exceptions, and authorizations for humanitarian assistance and trade to combat COVID-19 under OFAC’s sanctions program, please see OFAC’s June 10, 2022 Fact Sheet: Provision of Humanitarian Assistance and Trade to Combat COVID-19.

Updated: June 10, 2022

U.S. financial institutions are authorized to process transfers of funds or engage in trade finance transactions ordinarily incident and necessary to give effect to the transactions and activities authorized by Iran GL N-1, Syria GL 21A, and Venezuela GL 39A.  

Such financial institutions may rely on the originator of the funds transfer with regard to compliance with Iran GL N-1, Syria GL 21A, and Venezuela GL 39A, provided that the financial institution does not know or have reason to know that the funds transfer is not in compliance with such GLs. 

Updated: June 10, 2022

For the purposes of Iran GL N-1 and Syria GL 21A, services related to the prevention, diagnosis, or treatment of COVID-19 include, for example:  treatment of patients with suspected or confirmed COVID-19; training necessary for the safe and effective use, repair, or maintenance of goods for use in connection with the prevention, diagnosis, or treatment of COVID-19; water, sanitation, and hygiene promotion materials and supplies, and shelter activities to prevent or treat COVID-19, including Risk Communication and Community Engagement efforts related to COVID-19, and other goods and services, directly related to prevention or treatment of COVID-19; conduct of research into COVID-19; services necessary for the operation, maintenance, or repair of goods for use in connection with the prevention, diagnosis, or treatment of COVID-19; collaboration on the development or enhancement of information related to COVID-19 to the extent not authorized or exempt; development of medical devices or medicines to counteract COVID-19; conduct of clinical studies in connection with COVID-19; provision of public education in connection with COVID-19; and disposal of medical waste in connection with COVID-19, provided all conditions and limitations of Iran GL N-1 or Syria GL 21A are satisfied.

Transactions and activities related to the exportation or reexportation of such services include, for example:  processing and transfer of funds; payment of taxes, fees, and import duties; purchase or receipt of permits, licenses, or public utility services; making of shipping or cargo inspection arrangements; obtaining of insurance; arrangement of financing and payment; delivery of services; receipt of payment; and entry into contracts (including executory contracts), provided all conditions of Iran GL N-1 or Syria GL 21A are satisfied.  

As noted in Iran GL N-1 and Syria GL 21A, these general licenses do not authorize the unblocking of any property blocked pursuant to any part of 31 CFR chapter V, including property of the Government of Iran or property of the Government of Syria.  

Updated: June 10, 2022

In order to further aid the global fight against COVID-19, OFAC has extended time-limited general licenses, Iran GL N-1, Syria GL 21A, and Venezuela GL 39A (together, the COVID-19-related GLs), to continue to provide broad authorizations for certain COVID-19-related transactions and activities.  The general licenses expand upon longstanding humanitarian exemptions, exceptions, and authorizations in OFAC sanctions programs, which remain in effect (see OFAC’s June 16, 2022 Fact Sheet on the Provision of Humanitarian Assistance and Trade to Combat COVID-19) to cover additional COVID 19-related transactions and activities.  For example, Iran GL N-1 continues to allow for expanded authorizations under the Iran sanctions program to cover certain items that previously would have required a specific license for exportation or reexportation to Iran, such as certain COVID-19 testing or vaccine manufacturing equipment.  Both U.S. persons and non-U.S. persons whose activities are within U.S. jurisdiction — including exporters, nongovernmental organizations, international organizations, and financial institutions — may rely upon the authorizations in these COVID-19-related GLs provided they meet the applicable conditions.  All three GLs expire on June 17, 2023.  

The COVID-19-related GLs provide authorization that is independent of OFAC’s other humanitarian-related authorizations.  Accordingly, conditions and limitations included in other humanitarian-related authorizations do not apply to transactions and activities conducted pursuant to the COVID-19-related GLs, unless explicitly incorporated therein.  For example, for sales to Iran of agricultural commodities, food, medicine, and medical devices pursuant to the general license in 31 C.F.R. § 560.530, payment terms and financing must be limited to and consistent with those authorized by 31 C.F.R. § 560.532.  However, because Iran GL N-1 does not incorporate similar limitations on payment terms, COVID-19-related exports and reexports to Iran authorized by Iran GL N-1 are not subject to the payment terms in 31 C.F.R. § 560.532. 

Prior to the expiration of the COVID-19-related GLs, OFAC may issue additional guidance, as appropriate.  OFAC’s longstanding humanitarian exemptions, exceptions and authorizations in each of these sanctions programs will not be impacted by the expiration of these GLs.  For transactions not otherwise authorized or exempt, OFAC considers license requests on a case-by-case basis and prioritizes applications, compliance questions, and other requests related to humanitarian support for people in areas subject to comprehensive sanctions. 

Updated: June 10, 2022

Shipping companies are required to "block" packages in which a Specially Designated National ("SDN") or other blocked person has an interest. When a package is required to be "blocked," the shipper must retain the package rather than reject and return it to the sender. Blocking is not required if a general or specific license from OFAC authorizes the shipper to reject or process the package, or if the transaction is otherwise exempted from the prohibitions based on the type or content of the package. To request a license for the package’s release, apply online or send a letter with a detailed description of the package’s contents and an explanation of the parties involved in the transaction, along with a copy of the package’s air waybill or Customs Declaration and Dispatch form, to:

U.S. Department of the Treasury
Office of Foreign Assets Control
Licensing Division
1500 Pennsylvania Avenue, NW
Washington, DC 20220

There may have been one or more reasons the package was rejected.  For example, was it destined for Cuba and lacking a description of the contents?  Was it an unlicensed commercial shipment destined for North Korea?  Was it a personal gift destined for an individual in Iran with a stated value exceeding $100?  These examples are legitimate reasons for shipping companies to refuse to process such packages, such as packages that do not conform with shipping company guidelines and rules, as well as OFAC and other U.S. government regulations.  Not only could you be liable for attempting to send such packages, but the shipping companies also could be liable for their role in processing these.  See OFAC’s country program webpages for more information on the restrictions on shipments to high-risk jurisdictions, for example the Crimea region of Ukraine, Cuba, Iran, North Korea, or Syria. 

OFAC’s regulations are broader than the specific laws dealing with terrorists and persons who support them.  All individuals and entities that fall under U.S. jurisdiction should use OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List).  This list includes specially designated global terrorists and narcotics traffickers, among other designated persons, and is available on OFAC’s website.  In addition, OFAC maintains other sanctions lists that may have different prohibitions associated with each that apply to U.S. persons or transactions otherwise subject to U.S. jurisdiction.  It is important to note that some OFAC sanctions block categories of persons even if those persons do not appear on the SDN List.  For example, this is the case for any person that meets the definition of the “Government of Venezuela” in Executive Order 13884 of August 5, 2019 (“Blocking Property of the Government of Venezuela”).  It is also important to note that OFAC’s Cuba sanctions prohibit most transactions with Cuban nationals, wherever located.  U.S. persons are expected to exercise due diligence in determining whether any such persons are involved in a proposed transaction. 

No, OFAC does not issue non-inclusion certificates.

If you have questions about the authenticity of an OFAC document that is not publically posted on the OFAC website, you can contact OFAC and reference the specific case ID or FAC number that is included on the document.

• To verify a specific license, please contact the OFAC Licensing Division at 1-202-622-2480.
• To verify an SDN removal letter, please email ofac.reconsideration@treasury.gov.
• To verify another OFAC document, please contact the OFAC Compliance Division at 1-202-622-2490.

Yes. OFAC, therefore, strongly encourages parties to exercise due diligence when their business activities may touch on an OFAC-administered program and to contact OFAC if they have any questions about their transactions.