On December 9, 2022, the United Nations (UN) Security Council adopted UNSCR 2664, which establishes a humanitarian carveout to the asset freeze measure across United Nations sanctions regimes. The carveout enables the flow of legitimate humanitarian assistance and activities supporting the basic human needs of vulnerable populations while continuing to deny resources to malicious actors. On December 20, 2022, OFAC announced the issuance or amendment of four categories of general licenses (GLs) that support the conduct of U.S. government and humanitarian-related activities across a number of sanctions programs, including in OFAC sanctions programs that implement UN sanctions regimes.
Specifically, across a number of sanctions programs, OFAC issued or amended four categories of GLs authorizing the following activities:
- the official business of the U.S. government;
- the official business of certain international organizations and entities;
- transactions incident to certain humanitarian and other activities by nongovernmental organizations; and
- the provision of food and other agricultural commodities, medicine, medical devices, replacement parts and components, or software updates for medical devices for personal, non-commercial use.
For more information on the sanctions programs covered by these new or amended GLs, please see the Federal Register here and here. For information on specific exemptions or authorizations under a particular OFAC sanctions program, please see the relevant OFAC implementing regulations and OFAC’s Sanctions Programs and Country Information page.
For humanitarian-related activity that may fall outside the scope of these authorizations, OFAC considers specific license requests on a case-by-case basis and prioritizes license applications and other requests for guidance that are related to humanitarian activity. Please see OFAC’s License Application Page for additional details regarding the specific licensing process.
If individuals, nongovernmental organizations, international organizations, or other entities, including financial institutions, have questions about engaging in or processing transactions related to these authorizations, they may contact the OFAC Compliance Hotline by email OFAC_Feedback@treasury.gov or by phone at (800) 540-6322 or (202) 622-2490. As with specific license requests, OFAC prioritizes responding to questions related to humanitarian activity.