The US government has taken a stand on some of the disregarded recommendations from Syria-based development organizations.

The Supplemental Guidance improved clarity on some pressing questions related to authorized activities and transactions related to humanitarian assistance that are exempted from US sanctions.

The scope of the Supplemental Guidance includes US sanction programs targeting Syria, as well as other countries.

The Supplemental Guidance informs international organizations (IOs), non-governmental organizations (NGOs) and persons involved in the provision of food, agricultural commodities, medicine and medical devices, financial institutions and other service providers who support or facilitate related transactions for such persons, as well as entities of and the US government itself.

The Supplemental Guidance provides answer to the following questions:

• What do OFAC’s December 2022 General Licenses of the US government authorize?
• What activity falls under the official business of the US government?
• For the purposes of the December 2022 General License for International organizations (IO GL), what IO activity is authorized?
• For the purposes of the December 2022 General License for persons involved in the provision of food, other agricultural commodities, medicine, and medical devices (Ag-Med GL), what is authorized with respect to provision of food, other agricultural commodities, medicine, and medical devices?
• For the purposes of the December 2022 General License for NGOs (NGO GLs), what are examples of authorized activities?
• Are NGOs authorized to transfer funds to a blocked person in connection with an activity authorized pursuant to the December 2022 NGO General Licenses?
• Do the December 2022 General Licenses restrict the scope of any prior authorizations?
• In light of the issuance of the December 2022 General Licenses, are persons with OFAC specific licenses required to abide by the narrower scope of previously issued OFAC specific licenses?
• Are financial institutions authorized to process transactions or operate accounts for activity authorized by the December 2022 General Licenses?
• Do non-U.S. persons risk exposure to US sanctions for engaging in or facilitating transactions that are otherwise exempt or authorized for U.S. persons pursuant to the December 2022 General Licenses?
• Where can further information on compliance with US sanctions be obtained?

Please check the Supplemental Guidance for the Provision of Humanitarian Assistance issued February 27 of 2023 for more information:

https://home.treasury.gov/system/files/126/supplemental_ngo_humanitarian.pdf