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WASHINGTON—The U.S. Department of the Treasury stands with governments and citizens around the world in the global war against the COVID-19 global pandemic. The United States is committed to ensuring the international flow of humanitarian aid continues through legitimate and transparent channels.  Treasury supports the critical work of governments, international organizations, non-profit organizations, and individuals delivering medical supplies and humanitarian assistance to areas affected by COVID-19, including Iran, Venezuela, Syria, and North Korea. We simultaneously seek to mitigate the potential for this assistance to be diverted or misused by terrorists and other illicit actors. 

“Treasury sanctions do not target legitimate aid. U.S. sanctions programs allow humanitarian aid including medicine, medical devices, equipment, and agricultural products at any time. In the face of the COVID-19 global pandemic, we are acutely aware of the need for this aid to reach people,” said Secretary Steven T. Mnuchin.  “We are committed to working with financial institutions and non-profit organizations in their efforts to mitigate risks and allow humanitarian assistance and associated payments to flow to those who need it.”

While the vast majority of U.S.-based non-profit organizations are at low risk for terrorist financing, humanitarian organizations delivering assistance to conflict regions face a potentially higher risk of aid diversion in support of terrorist financing, corruption, or other illicit purposes.  Treasury reminds the financial sector that reputable, legitimate organizations implement a range of risk-mitigation measures including due diligence, governance, transparency, accountability, and other compliance measures, even in a crisis. This is consistent with the findings of the 2020 National Strategy for Combatting Terrorist and other Illicit Financing and the 2018 National Terrorist Financing Risk Assessment. We encourage the implementation of reasonable and risk-based AML measures to allow transparent, legitimate aid organizations to access financial services. 

Treasury’s Office of Foreign Assets Control (OFAC) continues to maintain broad exemptions and authorizations, across its sanctions programs including Iran, Venezuela, Syria, and DPRK, to ensure that U.S. sanctions do not hamper the transfer and delivery of humanitarian aid.  For transactions not already exempt or authorized by OFAC through existing general and specific licenses, OFAC maintains long-standing, favorable policies in multiple sanctions programs on granting specific licenses to support the provision of humanitarian assistance and the export of medicine and medical devices by U.S. persons.  OFAC stands prepared to issue additional guidance related to humanitarian exemptions as appropriate.

During this challenging time, Treasury is especially committed to working with the private sector, including financial institutions and non-profit organizations, to provide guidance and clarifications on U.S. sanctions and AML/CFT obligations related to humanitarian aid. For years, Treasury has brought together representatives from charities, financial institutions, and the government to discuss the factors that inform financial institutions’ AML and sanctions compliance programs.  We remain dedicated to continual dialogue with humanitarian, financial, and governmental stakeholders on these issues and welcome ongoing outreach and questions.

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