Exporters, non-governmental organizations, financial institutions, and individuals that are subject to US jurisdiction may require a license from the US Treasury Department’s Office of Foreign Assets Control (OFAC) to support COVID-19 relief efforts in territories subject to comprehensive US sanctions (e.g., Crimea, Cuba, Iran, North Korea, Syria) and territories whose governments are subject to stringent US sanctions (e.g., Venezuela). Their shipments may also be subject to the Export Administration Regulations (EAR). EU persons are also subject to EU sanctions regulations, which may differ significantly from US sanctions.
In this advisory we provide a brief summary of humanitarian general licenses (GLs) and license exceptions that may apply to COVID-19 relief efforts and other humanitarian activities. To assist in navigating these complex rules, we also provide a chart of relevant GLs and license exceptions contained in OFAC regulations and the EAR.