US issues general licenses to authorize certain Covid-related transactions with Iran, Syria and Venezuela

The US Office of Foreign Assets Control (OFAC) issued three separate and related general licenses (GLs) relevant to the sanction programmes targeting Iran, Syria, and Venezuela on June 17th. The three GLs authorize certain Covid-19-related transactions and activities, extending longstanding and still-in-effect humanitarian exemptions, exceptions, and authorizations already contained in the US sanctions programmes. All three GLs will expire on June 17th 2022, subject to any extension subsequently granted by OFAC.

Both US persons and non-US persons whose activities are within US jurisdiction can rely on the expanded authorizations.

OFAC FAQ 911 (issued contemporaneously with the GLs) confirms that non-US persons do not risk exposure under US sanctions for engaging in the activities that would be authorized under the new GLs, if engaged in by a US person.