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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 11 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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On September 24, 2021, Office of Foreign Assets Control (OFAC) issued two general licenses (GL) intending to alleviate the impact of U.S. sanctions on civilians in Afghanistan. Specifically, OFAC issued <a href="https://home.treasury.gov/system/files/126/ct_gl14.pdf" target="_blank" rel="noopener">GL 14</a> &ldquo;Authorizing Humanitarian Activities in Afghanistan&rdquo; and <a href="https://home.treasury.gov/system/files/126/ct_gl15.pdf" target="_blank" rel="noopener">GL 15</a> &ldquo;Transactions Related to the Exportation or Reexportation of Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates in Afghanistan.&rdquo; Both GLs authorize certain transactions involving the Taliban or the Haqqani network, which are blocked pursuant to Executive Order 13224, and listed on the Specially Designated Nationals and Blocked Persons List.
GL 14 authorizes all transactions involving the Taliban or the Haqqani network, or any entity in which these hold 50% or greater interest, that are ordinarily incident and necessary for the provision of humanitarian assistance to Afghanistan by the U.S. government, nongovernmental organizations, the United Nations, certain development banks, and Red Cross and persons acting on behalf of these entities, including their employees and contractors. GL 14, however, does not authorize financial transactions with persons involved in the Taliban or the Haqqani network.
GL 15 authorizes all transactions involving the Taliban or the Haqqani network, or any entity in which these hold 50% or greater interest, 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, or to persons in third countries purchasing specifically for resale to Afghanistan. Covered items under GL 15 include agricultural commodities, medicine and medical devices. GL 15 does not authorize financial transactions with persons involved in the Taliban or the Haqqani network.
OFAC also released four related FAQs &ndash; <a href="https://home.treasury.gov/policy-issues/financial-sanctions/faqs/928" target="_blank" rel="noopener">928</a>, <a href="https://home.treasury.gov/policy-issues/financial-sanctions/faqs/929" target="_blank" rel="noopener">929</a>, <a href="https://home.treasury.gov/policy-issues/financial-sanctions/faqs/930" target="_blank" rel="noopener">930</a> and <a href="https://home.treasury.gov/policy-issues/financial-sanctions/faqs/931" target="_blank" rel="noopener">931</a>. FAQs 928-929 explain that U.S. sanctions on the Taliban and the Haqqani network do not prohibit the provision of humanitarian assistance to Afghanistan, and that the &ldquo;humanitarian assistance&rdquo; means, among other things, provision of relief services and non-commercial development projects that primarily benefit poor or at-risk populations or otherwise relieve human suffering. FAQ 930 explains that the U.S. sanctions do not prohibit the exportation or reexportation of agricultural commodities, medicine, and medical devices to Afghanistan, as set forth in GL 15. FAQ 931 explains that non-U.S. persons do not risk exposure to U.S. sanctions for engaging in transactions that U.S. persons would be authorized under GLs 14 and 15.

core/freeform

SmarTrade

Senior Legislative and Regulatory Policy Advisor

Scott E. Diamond

International Trade

OFAC Issues General Licenses Authorizing Humanitarian Activities and Export/Reexport of Certain Materials to Afghanistan