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463. Can nongovernmental organizations (NGOs) provide assistance to North Korea? If so, what types of assistance can NGOs provide? Can NGOs conduct transactions with the Government of North Korea?


Yes. Section 510.512(a) of the North Korea Sanctions Regulations, 31 CFR part 510 (NKSR), authorizes NGOs that have filed the report specified in § 510.512 to conduct transactions that are ordinarily incident and necessary to the following activities:

  1. activities to support humanitarian projects to meet basic human needs,, including disaster, drought, or flood relief; food, nutrition, or medicine distribution; the provision of health services; assistance for vulnerable or displaced populations, including individuals with disabilities and the elderly; and environmental programs and (the foregoing activities continue to include the distribution of clean water, bottled drinking water, and clothing, and provision of shelter);  
  2. activities to support democracy building, including rule of law, citizen participation, government accountability, universal human rights and fundamental freedoms, access to information, and civil society development projects;
  3. activities to support education at or below a secondary school level, including combating illiteracy, increasing access to education at the primary or secondary school level, and assisting education reform projects, provided that such education excludes the subjects of math, sciences, technology, engineering, and computer programming;
  4. activities to support non-commercial development projects directly benefiting civilians, including those related to health, food security, and water and sanitation;  
  5. activities to support environmental and natural resource protection, including the preservation and protection of threatened or endangered species, responsible and transparent management of natural resources, and the remediation of pollution or other environmental damage; and
  6. activities to support disarmament, demobilization, and reintegration (DDR) programs and peacebuilding, conflict prevent, and conflict resolution programs.

Such ordinarily incident and necessary transactions may include payment of reasonable and customary taxes, fees, and import duties to, and purchase of receipt of permits, licenses, or public utility services from the Government of North Korea.

In addition, for items that are not subject to the Export Administration Regulations (EAR), § 510.512(a) authorizes the export or reexport of items ordinarily incident and necessary to the activities described above, provided the items would be designated as EAR99 if located in the United States.  For more information about OFAC and Commerce licensing requirements relating to the export or reexport of items that are subject to the EAR to North Korea, please see FAQ 459.

In most instances, exporters or reexporters no longer need to obtain licenses from both the Department of Commerce’s Bureau of Industry and Security (BIS) and OFAC to engage in transactions related to the export or reexport of items to persons blocked pursuant to the NKSR.  Section 510.520 authorizes transactions that are ordinarily incident to the exportation or reexportation of items to North Korea if the exportation or reexportation of such items is authorized by BIS.  Authorization from BIS is required to export or reexport any item subject to the EAR to North Korea, except food and medicine classified as EAR99 (see also the general license § 510.521 for transactions related to the exportation or reexportation of qualifying food and medicine to North Korea that are not subject to the EAR).

Additionally, § 510.512(c) explicitly authorizes U.S. depository institutions, U.S.-registered brokers or dealers in securities, and U.S.-registered money transmitters to process transfers of funds on behalf of U.S. or third-country NGOs, including to or from North Korea, in support of the activities described above. 

Date Updated: February 15, 2024 

Date Released
March 1, 2018