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Financial Services Law Insights and Observations

OFAC issues supplemental guidance on humanitarian sanctions exceptions

Financial Crimes Of Interest to Non-US Persons OFAC Department of Treasury OFAC Sanctions OFAC Designations

Financial Crimes

On February 27, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued supplemental guidance for the provision of humanitarian assistance. As previously covered by InfoBytes, last December OFAC implemented a carveout from the asset freeze provisions of UN sanctions programs by issuing or amending several general licenses to ease the delivery of humanitarian aid and ensure a baseline of authorizations for the provision of humanitarian support across many sanctions programs. The 2023 fact sheet provides information for the U.S. government, international organizations and entities, nongovernmental organizations, persons involved in the distribution of food, agricultural commodities, medicine, and medical devices, and financial institutions and other service providers who support or facilitate these transactions. The action reflects “Treasury’s work to limit the unintended impact of sanctions by providing greater consistency and clarity across U.S. sanctions programs to help legitimate humanitarian assistance and related trade reach at-risk populations through transparent financial channels.”