No. The Taliban are designated as a Specially Designated Global Terrorist (SDGTs) under Executive Order (E.O.) 13224. The Haqqani Network is designated as an SDGT under E.O. 13224 and a Foreign Terrorist Organization (FTO) under section 219 of the Immigration and Nationality Act (INA). These sanctions do not prohibit U.S. persons from exporting or reexporting goods or services to Afghanistan, provided that the transactions do not involve sanctioned individuals or entities, or property in which a blocked person has an interest unless exempt from regulation or authorized by OFAC.
In addition, OFAC has issued Afghanistan-related General Licenses (GLs) 14, 15, 16, 17, 18, 19, and 20 under the Global Terrorism Sanctions Regulations, 331 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), and E.O. 13224, as amended. For a consolidated list of all relevant GLs and FAQs, please see OFAC’s humanitarian Fact Sheet, “Provision of Humanitarian Assistance to Afghanistan and Support for the Afghan People,” (this content was updated on April 13, 2022) which provides an overview of the relevant authorizations and guidance related to U.S. sanctions on the Taliban and the Haqqani Network.
The GLs mentioned above do not authorize any debit to a blocked account on the books of a U.S. financial institution and restrict certain financial or other transfers to specified blocked persons, including the Taliban, the Haqqani Network, or any entity in which the Taliban or the Haqqani Network owns, directly or indirectly, a 50 percent or greater interest.
For activity outside the scope of these GLs, OFAC may issue specific licenses on a case-by-case basis to authorize certain transactions involving U.S. persons or the U.S. financial system that may otherwise be prohibited by OFAC sanctions, provided those transactions are in the foreign policy interests of the United States.
If individuals, nongovernmental organizations, international organizations, companies, or financial institutions have questions about engaging in or processing transactions related to these authorizations, they may contact OFAC’s Sanctions Compliance and Evaluation Division most efficiently via the OFAC Compliance hotline. OFAC prioritizes license applications, compliance questions and other requests that are related to humanitarian support.