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993. What if a governing institution in Afghanistan is led by an individual who appears on the Office of Foreign Assets Control’s List of Specially Designated Nationals and Blocked Persons? 


Generally speaking, when a designated individual has a leadership role in a governing institution, the governing institution itself is not considered blocked.  Accordingly, engaging in a routine interaction with an agency in which a blocked individual is an official, but that does not involve the blocked individual in question, is not prohibited. 

In this case, Afghanistan-related General License (GL) 20  authorizes all transactions involving Afghanistan or governing institutions in Afghanistan that would otherwise be prohibited by OFAC-administered sanctions on the Taliban or the Haqqani Network, subject to certain conditions.  GL 20 also authorizes the payment of taxes, fees, or import duties, or the purchase of permits, licensing, or public utility services to blocked individuals that are in leadership roles of governing institutions in Afghanistan, provided that such payments do not relate to luxury items  or services.

As an example, if an international organization (IO), nongovernmental organization (NGO), or company needs to make a customs payment to a governing institution in Afghanistan led by a blocked individual, that is authorized.  Similarly, if an IO, NGO, or company is signing a contract to provide services to or on behalf of that governing institution, and the blocked individual appointed to lead that governing institution needs to sign the contract in their official capacity on behalf of the governing institution, that is authorized.  However, if the blocked individual requests that funds be provided directly to them, other than for the purpose of effecting the payment of taxes, fees, or import duties, or the purchase or receipt of permits, licenses, or public utility services or financial transfers, that would not be authorized by GL 20.

Date Released
February 25, 2022