OFAC Issues Licenses Authorizing Humanitarian Measures, Athletic Exchanges Between U.S. and Iran

September 11, 2013, Washington, D.C. – The Treasury Department’s Office of Foreign Assets Control (OFAC) issued two licenses on Tuesday that authorized humanitarian-related activities by nongovernmental organizations in Iran, as well as athletic exchanges between Iran and the United States.

General License E permits the exportation of services, and the transfer of funds, by nongovernmental organizations for a number of not-for-profit humanitarian activities which are aimed at benefiting the Iranian people.  These include: activities connected with humanitarian projects to meet basic human needs (such as the operation of orphanages and the distribution of donated articles, including food, medicine, and clothing), projects aimed at building human rights and democracy, wildlife and environmental conservation projects, and non-commercial reconstruction projects in response to natural disasters for a period of up to two years. 

General License F permits the importation and exportation of services which support amateur and professional sporting exchanges and activities involving Iran and the U.S.  It includes an authorization to participate in “activities related to exhibition matches and events, the sponsorship of players, coaching, refereeing, and training.”  This is noteworthy because there are a significant number of Iranian American coaches and referees in certain sports such as soccer who can now be recruited for service in Iran. 

General License F appears to be the product of, or at least influenced by, a case involving an Iranian tennis referee.   In May 2013, Adel Borghei was invited by the U.S. Tennis Association (USTA) to referee at the United States Open.  After entering the U.S., however, he was told that U.S. sanctions laws barred him from participating in the event.  Borghei’s lawyers submitted a request to OFAC for a specific license that would allow him to participate in the Open.  The request was granted.

In August 2012, PAAIA together with other organizations sent a letter to OFAC urging action to assist victims of an earthquake in Iran. A general license for earthquake assistance was issued that month.   In April 2013, PAAIA sent a letter to the Obama administration urging the president to implement recommendations to establish clear channels for humanitarian trade and family remittances to and from Iran.  In July, OFAC issued it was making additions to the list of medical supplies it permits to be exported to Iran, in addition to releasing new guidance on the sale of food, agricultural commodities, medicine, and medical devices by non-U.S. persons to Iran.

Click here to read OFAC’s announcement of General Licenses E and F.

Click here to read “OFAC’s Summer of Surprises” by Samuel Cutler, policy adviser at Ferrari & Associates, a Washington, D.C. boutique law firm specializing in US economic sanctions matters.


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