DEPARTMENT OF THE TREASURY
OFFICE OF FOREIGN ASSETS CONTROL
Fact Sheet: Provision of Humanitarian Assistance and Trade to Combat COVID-19
April 16, 2020
The United States is committed to ensuring that humanitarian assistance continues to reach atrisk populations through legitimate and transparent channels as countries across the globe fight the Coronavirus Disease 2019 (COVID-19). The sanctions programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) generally allow for legitimate humanitarian-related trade, assistance, or activity under existing laws and regulations. OFAC encourages those interested in providing such assistance during the COVID-19 crisis to avail themselves of longstanding exemptions, exceptions, and authorizations pertaining to humanitarian assistance and trade available in many U.S. sanctions programs. In the event that individuals, governments, or entities face sanctions-related challenges, have questions related to the provision of humanitarian assistance to sanctioned countries, or believe additional authorizations are needed, OFAC stands ready to provide guidance and respond to applications for specific licenses. 1
This Fact Sheet provides consolidated guidance highlighting the most relevant exemptions, exceptions, and authorizations for humanitarian assistance and trade under the OFACadministered Iran, Venezuela, North Korea, Syria, Cuba, and Ukraine/Russia-related sanctions programs. The information below is current and operative as of the date of publication of this Fact Sheet, unless or until modified. 2 For additional information, including the latest updates on the programs listed below, or for information on other sanctions programs, please refer to OFAC’s website.
Please note that persons interested in exporting Personal Protective Equipment (PPE) from the United States should review all relevant U.S. regulations, guidance, and rules, including the temporary rule issued by the Federal Emergency Management Agency (FEMA) on April 10, 2020, which prohibits the export from the United States of five types of PPE without explicit FEMA approval. The temporary rule is effective from April 7, 2020 to August 10, 2020.
1 Under certain sanctions programs, separate authorization may be required from other U.S. Government agencies, including the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), which maintains similar authorizations intended to support the people of sanctioned countries.
2 This Fact Sheet is informational, does not have the force of law, and does not supersede the actual legal provisions cited.
The Venezuela sanctions program is designed to limit the illegitimate former Maduro regime’s sources of revenue and hold accountable those who stand in the way of restoring democracy in Venezuela, while also ensuring the flow of humanitarian goods and services to the Venezuelan people. U.S. persons are not prohibited from engaging in transactions involving the country or people of Venezuela, provided that the Government of Venezuela, other blocked persons, or proscribed conduct are not involved. To ensure that humanitarian goods can reach the people of Venezuela despite a nexus to the Government of Venezuela, the United States maintains broad exemptions and authorizations that allow for the provision of humanitarian assistance and the commercial sale and export of agricultural commodities, food, medicine, and medical devices, to Venezuela.
Frequently Asked Questions (FAQs): The following OFAC FAQs provide information on the provision of humanitarian assistance to Venezuela.
• FAQ 519 – Guidance related to helping the Venezuelan people.
• FAQ 520 – Guidance related to sending U.S. origin food or medicine to Venezuela.
• FAQ 521 – Guidance related to long-term financing to the Government of Venezuela to help with the export or re-export of food, medicine, medical devices, and related items to Venezuela.
• FAQ 665 – Guidance related to supporting humanitarian efforts following the blocking of the Government of Venezuela.
General Licenses (GLs) and Specific Licensing: The following are GLs issued by OFAC related to humanitarian assistance and trade with Venezuela.
• General License 4C authorizes certain transactions ordinarily incident and necessary to the exportation or reexportation of agricultural commodities, medicine, medical devices, replacement parts and components for medical devices, or software updates for medical devices to Venezuela, or to persons in third countries purchasing specifically for resale to Venezuela. This includes testing kits, respiratory devices, personal protective equipment, and medicine used in the prevention, diagnosis, treatment, and recovery from COVID-19.
• General License 16C authorizes all transactions and activities ordinarily incident and necessary to processing noncommercial, personal remittances involving certain financial institutions, including Banco de Venezuela, S.A. Banco Universal (Banco de Venezuela), Banco Bicentenario del Pueblo, de la Clase Obrera, Mujer y Comunas, Banco Universal C.A. (Banco Bicentario del Pueblo), Banco del Tesoro, C.A. Banco Universal (Banco del Tesoro), and Banco Central de Venezuela (BCV). In addition, remittances with non-blocked Venezuelan financial institutions are not prohibited.
• General License 20B authorizes official activities of certain international organizations such as the United Nations, including its Programmes and Funds, and its Specialized Agencies and Related Organizations, as well as the International Committee of the Red Cross, among others, to engage in transactions involving BCV, or involving other Government of Venezuela persons to the extent the transactions are subject to U.S. jurisdiction.
• General License 26 authorizes the provision and receipt of nonscheduled emergency medical services and the provision of other medical services involving the Government of Venezuela.
• General License 29 authorizes non-governmental organizations to engage in transactions involving the Government of Venezuela in support of humanitarian projects, democracy building, education, non-commercial development projects directly benefiting the Venezuelan people, and environmental protection in Venezuela.
• General License 30 authorizes activities involving the Government of Venezuela that are ordinarily incident and necessary to operations or use of ports and airports in Venezuela.
• General License 33 authorizes, among other activity, all transactions involving the Government of Venezuela necessary to provide air ambulance and related medical services, including medical evacuation from Venezuela, for individuals in Venezuela.
• Specific Licensing: For transactions not otherwise authorized by OFAC general licenses, OFAC considers specific license requests on a case-by-case basis and prioritizes license applications, compliance questions, and other requests related to humanitarian support for the Venezuelan people.
Advisories or Other Guidance: The following are advisories or other guidance issued by OFAC related to humanitarian assistance for Venezuela.
Executive Orders (E.O.): The following are E.O.s related to humanitarian assistance for Venezuela.
• E.O. 13884 of August 5, 2019, which blocks the property and interests in property of the Government of Venezuela, includes Section 5, exempts transactions involving the Government of Venezuela that relate to the provision of articles such as food, clothing, and medicine intended to be used to relieve human suffering.