Yes, cash shipments to Afghanistan may be authorized under General Licenses (GL) 14, GL 18, GL 19, or GL 20  provided that they are ordinarily incident and necessary to effectuate the activities authorized by the GLs.  

As with all OFAC GLs, GLs 14, 18, 19, and 20 are “self-executing,” meaning that persons who determine that such activities are ordinarily incident and necessary to their authorized activities within the scope of the GLs may proceed without further assurances from OFAC.

Date Updated: February 25, 2022

Yes.  Transactions that are ordinarily incident and necessary to give effect to the activities authorized in General Licenses (GL) 14, GL 15, GL 16, GL 17, GL 18, GL 19, or GL 20, including clearing, settlement, and transfers through, to, or otherwise involving privately owned and state-owned Afghan depository institutions, are authorized pursuant to these GLs. 

In addition, foreign financial institutions may engage in or facilitate transactions that would be authorized for U.S. persons under GLs 14, 15, 16, 17, 18, 19, or 20 without 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.

Date Updated: February 25, 2022

Yes.  Support to municipal water systems by NGOs for projects that directly benefit the Afghan people or otherwise relieve human suffering that would otherwise be 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, because of transactions with the Taliban and/or Haqqani Network would be covered by General Licenses (GLs) 14 and 19.  GL 18 authorizes all transactions and activities with the Taliban and/or Haqqani Network otherwise prohibited under the GTSR or FTOSR that are for the conduct of the official business of certain IOs.  Thus, if support to municipal water systems is part of these IOs’ official business, then it would not be prohibited. 

For example, this could include providing technical support to a project related to clean drinking water or making improvements to water systems for the benefit of the Afghan people. 

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 GTSR, the FTOSR, or E.O. 13224, as amended, subject to limited conditions set forth in GL 20 paragraph (b).  GL 20 therefore also covers support to municipal water systems by NGOs, IOs, 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, 18, and 19. Where appropriate, U.S. persons may rely on the broader authorization in GL 20 instead of the authorizations in GLs 14, 18, and 19.

Date Updated: February 25, 2022

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

Yes.  Providing support to public hospitals, such as provision of health services, technical support, and institutional deliveries, as well as payments directly to healthcare workers, that would otherwise be 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, because of transactions with the Taliban and/or Haqqani Network are authorized under General Licenses (GLs) 14, 15, and 19. 

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 GTSR, the FTOSR, or E.O. 13224, as amended, subject to limited conditions set forth in GL 20 paragraph (b).  GL 20 therefore also covers support to public hospitals in Afghanistan (e.g., health services, facilities maintenance, and health worker salaries) 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

As one example, if a non-governmental organization is providing support directly to Afghan hospitals or healthcare workers but needs to sign a memorandum of understanding that involves the Taliban in order to provide such support directly to the Afghan people, this engagement would be authorized under General Licenses (GLs) 14 and 19.

Other examples of engagement with the Taliban and the Haqqani Network that are authorized under GLs 14 and 19 if they are ordinarily incident and necessary to activities authorized by these GLs include: (i) general coordination on delivery and provision of humanitarian aid or shipments; (ii) administrative issues involving importation of goods; (iii) attendance at donor coordination meetings; (iv) sharing descriptions of projects; (v) coordination with regard to travel or project locations; (vi) participation in technical working groups; and (vii) sharing of office space.

In addition, payments of taxes, fees, or import duties to, or the purchase or receipt of permits, licenses, or public utility services from, 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, are authorized under GLs 14 and 19, if ordinarily incident and necessary to activities authorized by the GLs.  

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 transactions involving the Taliban or the Haqqani Network that are authorized under GLs 14 and 19.  

As noted in FAQ 996, the authorization in Afghanistan-related GL 20 may overlap with the authorizations in Afghanistan-related GLs 14 and 19.  Where appropriate, U.S. persons may rely on the broader authorization in GL 20 instead of the authorizations in GLs 14 and 19. 

Date Updated: February 25, 2022

Yes.  Both U.S. and non-U.S. companies can ship food to Afghanistan, and banks can process financial transfers and other transactions associated with food shipments to Afghanistan.

As described in FAQ 930, U.S. sanctions do not specifically prohibit the exportation or reexportation of agricultural commodities, medicine, and medical devices to Afghanistan.

OFAC has also issued Afghanistan-related General License (GL) 15, which authorizes U.S. persons to engage in all transactions that are ordinarily incident and necessary to the exportation or reexportation of agricultural commodities, medicine, medical devices, replacement parts, and components for medical devices, or software updates for medical devices to Afghanistan, as those terms are defined in GL 15, as well as to persons in third countries purchasing specifically for resale to Afghanistan, and that may involve 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 subject to certain conditions.  FAQ 931 provides further guidance that non-U.S. persons may engage in or facilitate transactions that would be authorized for U.S. persons under GL 15.

GL 15 also authorizes U.S. persons to engage in transactions or activities that are ordinarily incident and necessary to authorized exports or reexports, including the processing of financial transactions and related clearing and settlement involving privately-owned and state-owned banks in Afghanistan.  

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 shipments of food and agricultural products to Afghanistan and banks’ processing of these transactions.

As noted in FAQ 996, the authorization in Afghanistan-related GL 20 may overlap with the authorization in Afghanistan-related GL 15.  Where appropriate, U.S. persons may rely on the broader authorization in GL 20 instead of the authorization in GL 15. 

Date Updated: February 25, 2022