Yes. There may be exceptions to sanctions prohibitions. Exceptions may take the form of authorizations, such as general licenses and specific licenses, or exemptions.
OFAC issues general licenses in most of its sanctions programs to authorize certain transactions that would otherwise be prohibited, such as transactions related to humanitarian activities or official business of the U.S. government. General licenses are self-executing, meaning they allow persons to engage in certain transactions involving the United States or U.S. persons without needing to apply for a specific license provided the transactions meet certain terms and conditions as described in the general license.
OFAC may also issue specific licenses on a case-by-case basis. In contrast to general licenses, which authorize certain transactions for all persons who meet the conditions described in the license, specific licenses only authorize the licensee(s) to engage in certain transactions that would otherwise be prohibited. For guidance on how to request and apply for a specific license, please see 31 CFR § 501.801 and the License Application page on OFAC’s website.
Exceptions may also take the form of exemptions, meaning certain types of transactions are exempt from sanctions and therefore not prohibited. For example, in certain sanctions programs transactions involving personal communications, humanitarian donations, information or informational materials, and travel are exempt from relevant prohibitions.
Most OFAC sanctions programs have certain exceptions, but exceptions may vary in type and scope across different sanctions programs. For information on the authorizations or exemptions under a particular OFAC sanctions program, please see the relevant OFAC implementing regulations and the Sanctions Programs and Country Information page on OFAC’s website.
Date Updated: August 21, 2024.