U.S. financial institutions may operate accounts, including processing funds transfers, for persons engaging in activities authorized by the GLs related to: (i) the official business of the U.S. government, (ii) official business of certain international organizations and entities, (iii) certain humanitarian and other specified activities by nongovernmental organizations (NGOs), and (iv) the provision of agricultural commodities, medicine, medical devices, replacement parts and components, or software updates for medical devices for personal, non-commercial use. In assessing whether a particular transaction is in compliance with such GLs, financial institutions may reasonably rely upon the information available to them in the ordinary course of business, provided that the financial institution does not know or have reason to know that the transaction is outside the scope of the applicable GL.
Separately, non-U.S. persons, including NGOs and other entities, as well as foreign financial institutions facilitating or assisting these activities, do not risk exposure to U.S. sanctions for engaging in or facilitating transactions that are otherwise exempt or authorized for U.S. persons pursuant to these GLs.
For general information on OFAC’s due diligence expectations and compliance programs, please see A Framework for OFAC Compliance Commitments and FAQ 819.
If financial institutions have questions about engaging in or processing transactions related to these authorizations, they may contact the OFAC Compliance Hotline by email at OFAC_Feedback@treasury.gov or by phone at (800) 540-6322 or (202) 622-2490. OFAC prioritizes responding to questions related to humanitarian activity.