No. OFAC’s action of December 20, 2022 does not restrict the scope of any existing exemptions or OFAC authorizations for humanitarian activities, including existing general licenses authorizing certain NGO activities in sanctioned jurisdictions such as the Crimea Region of Ukraine, Iran, and Syria, which have not been amended by this action, and pre-existing web general licenses that have been incorporated into the relevant program regulations, such as Venezuela GL 20B. Persons conducting humanitarian activities pursuant to these programs may continue to rely on existing exemptions and OFAC authorizations, subject to the applicable conditions and limitations, which may differ by sanctions program.
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.