On April 16, 2020, the Office of Foreign Assets Control (OFAC) issued a Fact Sheet highlighting the most relevant exemptions, exceptions, and authorizations for humanitarian assistance and trade under the Iran, Venezuela, North Korea, Syria, Cuba, and Ukraine/Russia-related sanctions programs. The Fact Sheet outlines specific guidance for OFAC-administered sanctions programs related to personal protective equipment (PPE) and other Coronavirus Disease 2019 (COVID-19)-related humanitarian assistance and trade.
In its Iran-specific section of the Fact Sheet, OFAC states:
“For COVID-19 related support, Treasury continues to stress that U.S. and non-U.S. persons may provide such humanitarian goods — including medicine and medical devices — to Iran under existing exemptions, exceptions, and authorizations in U.S. sanctions laws and regulations. For example, most medicine and medical devices, including certain personal protective equipment and other items used for COVID-19-related treatment such as medical gowns, medical eyeshields and goggles, surgical gloves, face shields, certain respirators and masks such as N95, N99, and N100 masks, and certain ventilators, already qualify for export and reexport to Iran under general licenses, without the need for further authorization from OFAC. There are certain limited categories of items that may also be helpful for COVID-19-related assistance (e.g., oxygen generators, full face mask respirators including Powered Air Purifying Respirators, certain diagnostic medical imaging equipment, and certain decontamination equipment), for which OFAC’s regulations set forth a specific licensing policy for review of license applications on a case-by-case basis due to concerns about potential end use of these specific items. OFAC is prioritizing and expediting review of these license requests.”
By Chamber Staff