OFAC Issues General License No. 8, Reversing Sanctions Designation of Central Bank of Iran for Humanitarian Trade

On February 27, 2020, the U.S. Treasury’s Office of Foreign Assets Control (OFAC) issued General License 8 “Authorizing Certain Humanitarian Trade Transactions Involving the Central Bank of Iran.”

This move comes as mounting humanitarian pressure demonstrates the harmful impacts of the September 20, 2019 designation of the Central Bank of Iran (CBI) as a terrorist entity (pursuant to Executive Order 13224). That designation meant that U.S. persons could not engage in any transaction or deal in the property or interests in property of the CBI. The problem is that the Iranian Government provides universal healthcare to Iranian citizens, and the CBI plays a significant role in humanitarian trade with Iran. When the September 20th CBI designation was announced, it did not replicate the exemptions for humanitarian trade, leaving many charity and aid organizations in limbo.

General License 8 now permits certain humanitarian transactions and activities involving the CBI that would have been allowed prior to the CBI’s designation last September. General License 8 does not permit humanitarian-related transactions with financial institutions that are listed as terrorist entities by the U.S. other than the CBI.