No. Non-U.S. persons may engage in or facilitate transactions that would be authorized for U.S. persons under Afghanistan-related GLs 14, 15, 16, 17, 18, 19 or 20without exposure to sanctions under the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), or Executive Order (E.O.) 13224, as amended.
For example, activity that would be authorized by GLs 14, 15, 16, 17, 18, 19, or 20 if engaged in by a U.S. person would not be considered “significant” for the purposes of a secondary sanctions determination under E.O. 13224, as amended. Accordingly, foreign financial institutions do not risk exposure to correspondent and payable-through account sanctions under E.O. 13224, as amended, if they knowingly conduct or facilitate a significant transaction on behalf of persons blocked under E.O. 13224, as amended, that would be authorized under GLs 14, 15, 16, 17, 18, 19, or 20 if engaged in by a U.S. person.
For more information on relevant authorizations and guidance for providing humanitarian assistance to Afghanistan, 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.
If individuals, entities, international organizations, or financial institutions have questions about engaging in or processing transactions related to these authorizations, they can contact OFAC’s Sanctions Compliance and Evaluation Division most efficiently via email at OFAC_Feedback@treasury.gov. Sanctions Compliance and Evaluation may also be reached via phone at (800) 540-6322 or (202) 622-2490. OFAC prioritizes license applications, compliance questions and other requests that are related to humanitarian support.
Date Updated: February 25, 2022