• OFAC Issues Two General Licenses Affecting Iranian Transactions and Sanctions Regulations
  • September 12, 2013
  • Law Firm: Duane Morris LLP - Philadelphia Office
  • On September 10, 2013, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued two General Licenses affecting the Iranian transactions and sanctions regulations. General License E authorizes certain services in support of nongovernmental organizations' (NGOs) activities in Iran. Unless otherwise prohibited, nongovernmental organizations are authorized to export or re-export services to or related to Iran in support of certain not-for-profit activities that are designed to directly benefit the Iranian people. The activities include those related to humanitarian projects to meet basic human needs in Iran, including the provision of donated health-related services; operation of orphanages; relief services related to natural disasters; distribution of donated articles, such as food, clothing and medicine that are intended to relieve human suffering; and donated training related to the above.

    In addition, General License E authorizes activities related to non-commercial reconstruction projects in response to natural disasters for a period of up to two years following the natural disaster; activities related to environmental and wildlife conservation projects in Iran involving endangered species; activities related to human rights and democracy building, which are more particularly set forth in General License E; and transfers of funds in support of activities as set forth in section (a) of General License E by a single NGO not exceeding USD $500,000 in the aggregate over a 12-month period.

    General License E requires NGOs to submit quarterly reports, which include detailed descriptions of the services provided, along with any Iranian NGOs, Government of Iran entities, Iranian financial institutions or other Iranian persons involved in the activities. For specific details regarding coverage and exclusions, please refer to General License E on OFAC's website.

    General License F authorizes certain services in support of professional and amateur sports activities and exchanges involving the United States and Iran.

    U.S. depository institutions or U.S. registered brokers or dealers in securities are authorized to process transfers of funds in furtherance of activities authorized by General License F as long as the transfer is consistent with other regulations contained in 31 C.F.R. Part 560.

    General License F "does not authorize any transaction by a U.S.-owned or -controlled foreign entity otherwise prohibited by 31 C.F.R. ยง 560.215 if the transaction would be prohibited by any other part of chapter V if engaged in by a U.S. person or in the United States."