Financial institutions participating in the humanitarian channel in Qatar (HC) have received specific guidance from the U.S. government. Companies interested in participating in transactions under the HC should coordinate directly with the Qatari International Media Office at firstname.lastname@example.org and should not hesitate to contact the OFAC Compliance Hotline with specific questions.
OFAC’s requirements related to humanitarian trade with Iran have not changed. Companies interested in participating in transactions pursuant to existing exceptions and authorizations for the conduct of humanitarian trade with Iran may continue to do so outside of the HC. For example, certain humanitarian transactions involving the Central Bank of Iran and the National Iranian Oil Company are permissible under General License 8A (see also FAQ 823). OFAC FAQ 828 and our Guidance on the Sale of Food, Agricultural Commodities, Medicine, and Medical Devices by Non-U.S. Persons to Iran reflect OFAC’s longstanding regulations related to exports of humanitarian goods to Iran. Iranian financial institutions designated under Executive Order (E.O.) 13902 are subject to the exception in E.O. 13902 with respect to conducting or facilitating transactions for the provision (including any sale) of agricultural commodities, food, medicine, or medical devices to Iran.
U.S. persons and their owned or controlled foreign entities must continue to comply with the Iranian Transactions and Sanctions Regulations, 31 C.F.R. part 560 (ITSR), when conducting exports of humanitarian goods to Iran. Certain exports and sales of humanitarian goods to Iran are authorized pursuant to sections 560.530, 560.532, and 560.533 of the ITSR.