On October 25, 2019, the U.S. Departments of State and the Treasury announced a new humanitarian framework to assist foreign governments and foreign financial institutions in establishing payment mechanisms to facilitate humanitarian exports to Iran that are subject to enhanced due diligence. While the United States maintains broad exceptions and authorizations for the conduct of humanitarian trade with Iran, this humanitarian framework presents an additional, voluntary option for facilitating payment for exports of agricultural commodities, food, medicine, and medical devices to Iran. The SHTA is the first operational channel to be established under this humanitarian framework, in partnership with the Swiss government. Initial pilot transactions were successfully conducted in late January 2020, and the SHTA was formally established on 27 February 2020. Under the SHTA, participating financial institutions commit to conducting enhanced due diligence to ensure that humanitarian goods reach the people of Iran and are not misused by the Iranian regime.
For more information on the humanitarian mechanism as announced by the U.S. government, please refer to the guidance published on the Treasury’s website on October 25, 2019. Additional guidance for companies and financial institutions interested in participating in the SHTA can be found in the Treasury SHTA fact sheet and OFAC FAQs 825 and 826.