Yes. Even to the extent doing so would involve transacting with the Taliban and/or Haqqani Network, NGOs can make salary support or stipend payments directly to healthcare workers, such as doctors at public hospitals or healthcare workers at community clinics, under General License (GL) 14 and GL 19. Similarly, even to the extent doing so would involve transacting with the Taliban and/or Haqqani Network, NGOs can make such salary support or stipend payments directly to teachers, including teachers at Afghan public and private schools, under GL 19. Under GL 18, certain IOs can provide such salary support payments directly to healthcare workers and teachers.
In addition, OFAC has issued Afghanistan-related GL 20 , which, to the extent authorization is required, authorizes all transactions involving Afghanistan or governing institutions in Afghanistan prohibited 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, subject to limited conditions set forth in GL 20 paragraph (b). GL 20 therefore also covers salary support or stipend payments directly to teachers, including teachers at Afghan public and private schools, and healthcare workers by NGOs or other persons.
As noted in FAQ 996, the authorization in Afghanistan-related GL 20 may overlap with the authorizations in Afghanistan-related GLs 14, 15, and 19. Where appropriate, U.S. persons may rely on the broader authorization in GL 20 instead of the authorizations in GLs 14, 15, and 19.
Date Updated: February 25, 2022