No. Non-U.S. persons do not risk exposure under U.S. sanctions for engaging in certain activities to respond to COVID-19 that would be authorized under Iran GL N-2, Syria GL 21B, or Venezuela GL 39B, as appropriate, if engaged in by a U.S. person. This includes non-U.S. exporters, nongovernmental organizations, international organizations, and foreign financial institutions, as well as other non-U.S. persons engaging in certain activities to respond to COVID-19.
For additional information on humanitarian activities by non-U.S. persons in relation to sanctioned jurisdictions, please see FAQs 844, 884, and 885. For information specific to the provision of humanitarian assistance to the Venezuelan people, please see OFAC’s August 6, 2019 Fact Sheet: Guidance Related to the Provision of Humanitarian Assistance and Support to the Venezuelan People. For more information on other relevant exemptions, exceptions, and authorizations for humanitarian assistance and trade to combat COVID-19 under OFAC’s sanctions program, please see OFAC’s June 14, 2023 Fact Sheet: Provision of Humanitarian Assistance and Trade to Combat COVID-19 (originally issued April 16, 2020 and has since been updated every year).
Date Updated: June 14, 2023