CAF America Insider Blog

OFAC Announces New General Licenses for Afghanistan

December 23, 2021

Yesterday, the US Office of Foreign Assets Control (OFAC) released a series of six General Licenses for the provision of humanitarian assistance in Afghanistan. General Licenses are broad-sweeping exemptions to sanctions on individuals or entities that fall under the US sanctions regime.

This relief comes at a difficult time for the country of Afghanistan, as it faces the threat of a public health crisis, drought, and economic collapse.

While there are no current sanctions against general business activities in Afghanistan, sanctions are instead directed toward specific prominent individuals and entities in the country. For example, while the Afghan government is not sanctioned, many officials in the new Afghan regime are on the OFAC Specially Designated Nationals (SDN) list, turning any previous work in Afghanistan into a regulatory minefield.

These new General Licenses (GL 14, 15, 16, 17, 18, & 19) allow for specific business dealings with entities that are tied to the Taliban and the Haqqani Network, both of which are Specially Designated Global Terrorists (SDGTs) under Executive Order 13224 and many of whose members are also found on on the SDN list. The following activities are covered:

  1. Humanitarian Activities in Afghanistan (GL 14)
  2. Agricultural Commodities, Medicine, and Medical Devices (GL 15)
  3. Personal Remittances (GL 16)
  4. US Government Business (GL 17)
  5. Official Activities of Certain International Organizations and Other International Entities (GL 18)
  6. Certain Transactions in Support of Nongovernmental Organizations’ Activities in Afghanistan (GL 19)

See a full factsheet on the Afghanistan General Licenses on the OFAC website here.

These General Licenses go far to allow for more funding to aid the Afghan people, but donors should be careful to assess the risks of giving to Afghanistan even with these new permissions.

If you want to learn more about General Licenses, how they work, and how to design a grantmaking program that complies with all OFAC restrictions in highly-sanctioned countries, read CAF America’s white paper on the subject, co-authored with the Charity and Security Network.


 

About the author:

Jessie Krafft serves as the Senior Vice President of External Affairs. She is a leading expert in international grantmaking from the U.S. and Canada as well as in local country laws on foreign funding.

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