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afghanistan_sanctions_dataset

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Afghanistan-Related Sanctions

The sanctions program targets individuals, entities, and activities in Afghanistan to ensure humanitarian assistance flows while restricting funding to sanctioned groups.

{'Executive Orders': ['14064 - Protecting Certain Property of Da Afghanistan Bank for the Benefit of the People of Afghanistan', '13268 - Termination of Emergency With Respect to the Taliban and Amendment of EO 13224', '13224 - Blocking Property and Prohibiting Transactions With Persons Who Commit, Threaten To Commit, or Support Terrorism'], 'Statutes': ['International Emergency Economic Powers Act (IEEPA), 50 U.S.C. §§ 1701-1706', 'National Emergencies Act (NEA), 50 U.S.C. §§ 1601-1651']}

{'GL 14 - Humanitarian Activities': 'DEPARTMENT OF THE TREASURY\nWASHINGTON, D.C.\nOFFICE OF FOREIGN ASSETS CONTROL\nGlobal Terrorism Sanctions Regulations\n31 CFR Part 594\nForeign Terrorist Organizations Sanctions Regulations\n31 CFR Part 597\nExecutive Order 13224 of September 23, 2001\nBlocking Property and Prohibiting Transactions With Persons Who Commit, Threaten To\nCommit, or Support Terrorism, as Amended\nGENERAL LICENSE NO. 14\nAuthorizing Humanitarian Activities in Afghanistan\n(a) Except as provided in paragraph (b) of this general license, all transactions involving\nthe Taliban or the Haqqani Network, or any entity in which the Taliban or the Haqqani Network\nowns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest,\nprohibited by the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign\nTerrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), or Executive Order\n(E.O.) 13224, as amended, that are ordinarily incident and necessary to the provision of\nhumanitarian assistance to Afghanistan or other activities that support basic human needs in\nAfghanistan by the following entities and their employees, grantees, contractors, or other persons\nacting on their behalf are authorized:\n(1) The United States Government;\n(2) Nongovernmental organizations;\n(3) The United Nations, including its Programmes, Funds, and Other Entities and Bodies,\nas well as its Specialized Agencies and Related Organizations;\n(4) The International Centre for Settlement of Investment Disputes (ICSID) and the\nMultilateral Investment Guarantee Agency (MIGA);\n(5) The African Development Bank Group, the Asian Development Bank, the European\nBank for Reconstruction and Development, and the Inter-American Development Bank Group\n(IDB Group), including any fund entity administered or established by any of the foregoing;\n\n=== PAGE BREAK ===\n\n(6) The International Committee of the Red Cross and the International Federation of Red\nCross and Red Crescent Societies; and\n(7) The Islamic Development Bank.\n(b) This general license does not authorize:\n(1) Financial transfers to any blocked person described in paragraph (a), other than for\nthe purpose of effecting the payment of taxes, fees, or import duties, or the purchase or receipt of\npermits, licenses, or public utility services;\n(2) Any debit to an account on the books of a U.S. financial institution of any blocked\nperson blocked described in paragraph (a); or\n(3) Any transactions or activities otherwise prohibited by the GTSR, the FTOSR, or any\nother part of 31 CFR chapter V, or E.O. 13224, as amended.\nNote to General License No. 14. Nothing in this general license relieves any person\nfrom compliance with any other Federal laws or requirements of other Federal agencies.\n___________________________\nBradley T. Smith\nActing Director\nOffice of Foreign Assets Control\nDated: September 24, 2021\n\n=== PAGE BREAK ===', 'GL 15 - Agricultural & Medical Transactions': 'DEPARTMENT OF THE TREASURY\nWASHINGTON, D.C.\nOFFICE OF FOREIGN ASSETS CONTROL\nGlobal Terrorism Sanctions Regulations\n31 CFR Part 594\nForeign Terrorist Organizations Sanctions Regulations\n31 CFR Part 597\nExecutive Order 13224 of September 23, 2001\nBlocking Property and Prohibiting Transactions With Persons Who Commit, Threaten To\nCommit, or Support Terrorism, as Amended\nGENERAL LICENSE NO. 15\nTransactions Related to the Exportation or Reexportation of\nAgricultural Commodities, Medicine, Medical Devices, Replacement Parts and\nComponents, or Software Updates in Afghanistan\n(a) Except as provided in paragraph (c) of this general license, all transactions involving\nthe Taliban or the Haqqani Network, or any entity in which the Taliban or the Haqqani Network\nowns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest,\nprohibited by the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign\nTerrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), or Executive Order\n(E.O.) 13224, as amended, that are ordinarily incident and necessary to the exportation or\nreexportation of agricultural commodities, medicine, medical devices, replacement parts and\ncomponents for medical devices, or software updates for medical devices to Afghanistan, or to\npersons in third countries purchasing specifically for resale to Afghanistan, are authorized.\n(b) Covered items. For the purposes of this general license, agricultural commodities,\nmedicine, and medical devices are defined as follows:\n(1) Agricultural commodities. For the purposes of this general license, agricultural\ncommodities are:\n(i) Products that fall within the term “agricultural commodity” as defined in section 102\nof the Agricultural Trade Act of 1978 (7 U.S.C. 5602); and\n(ii) That are intended for ultimate use in Afghanistan as:\n(A) Food for humans (including raw, processed, and packaged foods; live animals;\nvitamins and minerals; food additives or supplements; and bottled drinking water) or animals\n(including animal feeds);\n\n=== PAGE BREAK ===\n\n(B) Seeds for food crops;\n(C) Fertilizers or organic fertilizers; or\n(D) Reproductive materials (such as live animals, fertilized eggs, embryos, and semen)\nfor the production of food animals.\n(2) Medicine. For the purposes of this general license, medicine is an item that falls\nwithin the definition of the term “drug” in section 201 of the Federal Food, Drug, and Cosmetic\nAct (21 U.S.C. 321).\n(3) Medical devices. For the purposes of this general license, a medical device is an item\nthat falls within the definition of “device” in section 201 of the Federal Food, Drug, and\nCosmetic Act (21 U.S.C. 321).\n(c) This general license does not authorize:\n(1) Financial transfers to any blocked person described in paragraph (a), other than for\nthe purpose of effecting the payment of taxes, fees, or import duties to, or the purchase or receipt\nof permits, licenses, or public utility services;\n(2) Any debit to an account on the books of a U.S. financial institution of any blocked\nperson described in paragraph (a); or\n(3) Any transactions or activities otherwise prohibited by the GTSR, the FTOSR, or any\nother part of 31 CFR chapter V, or E.O. 13224, as amended.\nNote to General License No. 15. Nothing in this general license relieves any person\nfrom compliance with any other Federal laws or requirements of other Federal agencies.\n___________________________\nBradley T. Smith\nActing Director\nOffice of Foreign Assets Control\nDated: September 24, 2021\n\n=== PAGE BREAK ===', 'GL 16 - Personal Remittances': 'DEPARTMENT OF THE TREASURY\nWASHINGTON, D.C.\nOFFICE OF FOREIGN ASSETS CONTROL\nGlobal Terrorism Sanctions Regulations\n31 CFR Part 594\nForeign Terrorist Organizations Sanctions Regulations\n31 CFR Part 597\nExecutive Order 13224 of September 23, 2001\nBlocking Property and Prohibiting Transactions With Persons Who Commit, Threaten To\nCommit, or Support Terrorism, as Amended\nGENERAL LICENSE NO. 16\nAuthorizing Noncommercial, Personal Remittances to Afghanistan\n(a) Except as provided in paragraph (c) of this general license, all transactions involving\nthe Taliban or the Haqqani Network, or any entity in which the Taliban or the Haqqani Network\nowns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest,\nprohibited by the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign\nTerrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), or Executive Order\n(E.O.) 13224, as amended, that are ordinarily incident and necessary to the transfer of\nnoncommercial, personal remittances to Afghanistan, including through Afghan depository\ninstitutions, are authorized.\nNote to paragraph (a). Noncommercial, personal remittances do not include charitable\ndonations of funds to or for the benefit of an entity or funds transfers for use in supporting or\noperating a business, including a family-owned business.\n(b)Transferring institutions may rely on the originator of a funds transfer with regard to\ncompliance with paragraph (a), provided that the transferring institution does not know or have\nreason to know that the funds transfer is not in compliance with paragraph (a).\n(c)This general license does not authorize:\n(1)Financial transfers to any blocked person described in paragraph (a) of this general\nlicense, other than for the purpose of effecting the payment of reasonable and customary taxes,\nfees, or other duties; or\n(2)Any debit to an account on the books of a U.S. financial institution of any blocked\nperson described in paragraph (a); or\n\n=== PAGE BREAK ===\n\n(3) Any transactions or activities otherwise prohibited by the GTSR, the FTOSR, or any\nother part of 31 CFR chapter V, or E.O. 13224, as amended.\nNote to General License No. 16. Nothing in this general license relieves any person\nfrom compliance with any other Federal laws or requirements of other Federal agencies.\n___________________________\nAndrea M. Gacki\nDirector\nOffice of Foreign Assets Control\nDated: December 10, 2021\n\n=== PAGE BREAK ===', 'GL 17 - U.S. Government Business': 'DEPARTMENT OF THE TREASURY\nWASHINGTON, D.C.\nOFFICE OF FOREIGN ASSETS CONTROL\nGlobal Terrorism Sanctions Regulations\n31 CFR part 594\nForeign Terrorist Organizations Sanctions Regulations\n31 CFR part 597\nExecutive Order 13224 of September 23, 2001\nBlocking Property and Prohibiting Transactions With Persons Who Commit, Threaten To\nCommit, or Support Terrorism, as Amended\nGENERAL LICENSE NO. 17\nOfficial Business of the United States Government\n(a) Except as provided in paragraph (b) of this general license, all transactions and\nactivities involving the Taliban or the Haqqani Network, or any entity in which the Taliban or\nthe Haqqani Network owns, directly or indirectly, individually or in the aggregate, a 50 percent\nor greater interest, prohibited by the Global Terrorism Sanctions Regulations, 31 CFR part 594\n(GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR),\nor Executive Order (E.O.) 13224, as amended, that are for the conduct of the official business of\nthe United States Government by employees, grantees, or contractors thereof are authorized.\n(b) This general license does not authorize:\n(1) Financial transfers to any blocked person described in paragraph (a), other than for\nthe purpose of effecting the payment of taxes, fees, or import duties, or the purchase or receipt of\npermits, licenses, or public utility services;\n(2) Any debit to an account on the books of a U.S. financial institution of any blocked\nperson described in paragraph (a); or\n(3) Any transactions or activities otherwise prohibited by the GTSR, the FTOSR, or any\nother part of 31 CFR chapter V, or E.O. 13224, as amended.\n___________________________\nAndrea M. Gacki\nDirector\nOffice of Foreign Assets Control\nDated: December 22, 2021\n\n=== PAGE BREAK ===', 'GL 18 - International Organizations': 'DEPARTMENT OF THE TREASURY\nWASHINGTON, D.C.\nOFFICE OF FOREIGN ASSETS CONTROL\nGlobal Terrorism Sanctions Regulations\n31 CFR part 594\nForeign Terrorist Organizations Sanctions Regulations\n31 CFR part 597\nExecutive Order 13224 of September 23, 2001\nBlocking Property and Prohibiting Transactions With Persons Who Commit, Threaten To\nCommit, or Support Terrorism, as Amended\nGENERAL LICENSE NO. 18\nOfficial Activities of Certain International Organizations and Other International Entities\n(a) Except as provided in paragraph (b) of this general license, all transactions and\nactivities involving the Taliban or the Haqqani Network, or any entity in which the Taliban or\nthe Haqqani Network owns, directly or indirectly, individually or in the aggregate, a 50 percent\nor greater interest, prohibited by the Global Terrorism Sanctions Regulations, 31 CFR part 594\n(GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR),\nor Executive Order (E.O.) 13224, as amended, that are for the conduct of the official business of\nthe following entities by employees, grantees, or contractors thereof are authorized:\n(1) The United Nations, including its Programmes, Funds, and Other Entities and Bodies,\nas well as its Specialized Agencies and Related Organizations;\n(2) The International Centre for Settlement of Investment Disputes (ICSID) and the\nMultilateral Investment Guarantee Agency (MIGA);\n(3) The African Development Bank Group, the Asian Development Bank, the European\nBank for Reconstruction and Development, and the Inter-American Development Bank Group\n(IDB Group), including any fund entity administered or established by any of the foregoing;\n(4) The International Committee of the Red Cross and the International Federation of Red\nCross and Red Crescent Societies; and\n(5) The Islamic Development Bank.\n\n=== PAGE BREAK ===\n\n(b) This general license does not authorize:\n(1) Financial transfers to any blocked person described in paragraph (a), other than for\nthe purpose of effecting the payment of taxes, fees, or import duties, or the purchase or receipt of\npermits, licenses, or public utility services;\n(2) Any debit to an account on the books of a U.S. financial institution of any blocked\nperson described in paragraph (a); or\n(3) Any transactions or activities otherwise prohibited by the GTSR, the FTOSR, or any\nother part of 31 CFR chapter V, or E.O. 13224, as amended.\n___________________________\nAndrea M. Gacki\nDirector\nOffice of Foreign Assets Control\nDated: December 22, 2021\n\n=== PAGE BREAK ===', 'GL 19 - NGO Transactions': 'DEPARTMENT OF THE TREASURY\nWASHINGTON, D.C.\nOFFICE OF FOREIGN ASSETS CONTROL\nGlobal Terrorism Sanctions Regulations\n31 CFR part 594\nForeign Terrorist Organizations Sanctions Regulations\n31 CFR part 597\nExecutive Order 13224 of September 23, 2001\nBlocking Property and Prohibiting Transactions With Persons Who Commit, Threaten To\nCommit, or Support Terrorism, as Amended\nGENERAL LICENSE NO. 19\nCertain Transactions in Support of Nongovernmental Organizations’\nActivities in Afghanistan\n(a) Except as provided in paragraph (c) of this general license, all transactions and\nactivities involving the Taliban or the Haqqani Network, or any entity in which the Taliban or\nthe Haqqani Network owns, directly or indirectly, individually or in the aggregate, a 50 percent\nor greater interest, prohibited by the Global Terrorism Sanctions Regulations, 31 CFR part 594\n(GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR),\nor Executive Order (E.O.) 13224, as amended, that are ordinarily incident and necessary to the\nactivities described in paragraph (b) by nongovernmental organizations are authorized.\n(b) The activities referenced in paragraph (a) of this general license are as follows:\n(1) Activities to support humanitarian projects to meet basic human needs in Afghanistan,\nincluding drought and flood relief; food, nutrition, and medicine distribution; the provision of\nhealth services; assistance for vulnerable or displaced populations, including individuals with\ndisabilities, the elderly, and survivors of sexual- and gender-based violence; and environmental\nprograms;\n(2) Activities to support the following in Afghanistan: rule of law, citizen participation,\ngovernment accountability and transparency, human rights and fundamental freedoms, access to\ninformation, and civil society development projects;\n(3) Activities to support education in Afghanistan, including combating illiteracy,\nincreasing access to education, international exchanges, and assisting education reform projects;\n(4) Activities to support non-commercial development projects directly benefitting the\nAfghan people, including related to health, food security, and water and sanitation; and\n\n=== PAGE BREAK ===\n\n(5) Activities to support environmental and natural resource protection in Afghanistan,\nincluding the preservation and protection of threatened or endangered species, responsible and\ntransparent management of natural resources, and the remediation of pollution or other\nenvironmental damage.\n(c) This general license does not authorize:\n(1) Financial transfers to any blocked person described in paragraph (a), other than for\nthe purpose of effecting the payment of taxes, fees, or import duties, or the purchase or receipt of\npermits, licenses, or public utility services;\n(2) Any debit to an account on the books of a U.S. financial institution of any blocked\nperson described in paragraph (a); or\n(3) Any transactions or activities otherwise prohibited by the GTSR, the FTOSR, or any\nother part of 31 CFR chapter V, or E.O. 13224, as amended.\nNote to General License No. 19. Nothing in this general license relieves any person\nfrom compliance with any other Federal laws or requirements of other Federal agencies.\n___________________________\nAndrea M. Gacki\nDirector\nOffice of Foreign Assets Control\nDated: December 22, 2021\n\n=== PAGE BREAK ===', 'GL 20 - Governing Institutions': 'OFFICE OF FOREIGN ASSETS CONTROL\nGlobal Terrorism Sanctions Regulations\n31 CFR part 594\nForeign Terrorist Organizations Sanctions Regulations\n31 CFR part 597\nExecutive Order 13224 of September 23, 2001\nBlocking Property and Prohibiting Transactions With Persons Who Commit, Threaten To\nCommit, or Support Terrorism, as Amended\nGENERAL LICENSE NO. 20\nAuthorizing Transactions Involving Afghanistan or Governing Institutions in Afghanistan\n(a) To the extent authorization is required and except as provided in paragraph (b) of this\ngeneral license, all transactions involving Afghanistan or governing institutions in Afghanistan\nprohibited by the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign\nTerrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), or Executive Order\n(E.O.) 13224, as amended, are authorized.\n(b) This general license does not authorize:\n(1) Financial transfers to the Taliban, the Haqqani Network, any entity in which the\nTaliban or the Haqqani Network owns, directly or indirectly, individually or in the aggregate, a\n50 percent or greater interest, or any blocked individual who is in a leadership role of a\ngoverning institution in Afghanistan, other than for the purpose of effecting the payment of\ntaxes, fees, or import duties, or the purchase or receipt of permits, licenses, or public utility\nservices, provided that such payments do not relate to luxury items or services;\n(2) Transfers of luxury items or services to any blocked person described in paragraph\n(b)(1) of this general license;\n(3) Any debit to an account on the books of a U.S. financial institution of any blocked\nperson; or\n(4) Any transactions involving any person blocked pursuant to the GTSR, the FTOSR, or\nE.O. 13224, as amended, other than the blocked persons described in paragraph (b)(1) of this\ngeneral license, unless separately authorized.\nNote 1 to General License No. 20. Nothing in this general license relieves any person\nfrom compliance with any other Federal laws or requirements of other Federal agencies.\n\n=== PAGE BREAK ===\n\nNote 2 to General License No. 20. Nothing in this general license affects the property\nor interests in property of Da Afghanistan Bank that are protectively blocked pursuant to\nE.O. 14064 of February 11, 2022, “Protecting Certain Property of Da Afghanistan Bank for the\nBenefit of the People of Afghanistan.”\n___________________________\nAndrea M. Gacki\nDirector\nOffice of Foreign Assets Control\nDated: February 25, 2022\n\n=== PAGE BREAK ==='}

{'FAQ 928': 'Guidance on U.S. sanctions on the Taliban and humanitarian assistance', 'FAQ 929': 'Guidance on humanitarian assistance to Afghanistan', 'FAQ 930': 'Guidance on agricultural exports and medicine to Afghanistan', 'FAQ 949': 'Guidance on personal remittances to Afghanistan'}

Fact Sheet: Provision of Humanitarian Assistance to Afghanistan and Support for the Afghan People April 13, 2022 The United States is the largest single provider of humanitarian assistance in Afghanistan and is committed to continuing to support the Afghan people. The Treasury Department seeks to ensure that humanitarian assistance and other support to the Afghan people (including COVID- 19 related assistance) can continue to flow directly to Afghanistan through legitimate and transparent channels, including the U.S. government, international organizations (IOs), and nongovernmental organizations (NGOs), and that such entities can continue to engage in humanitarian assistance and certain other activities that support the Afghan people. In addition, Treasury seeks to enable Afghan-Americans and Afghans in the United States and around the world to continue to support their families in Afghanistan through personal remittances. As part of the United States’ commitment to supporting the Afghan people, Treasury’s OFAC is issuing this Fact Sheet to emphasize that U.S. sanctions on the Taliban and the Haqqani Network do not stand in the way of transactions and activities that support basic human needs of the people in Afghanistan. This Fact Sheet also provides consolidated guidance highlighting the most relevant authorizations and guidance for humanitarian and other assistance related to Afghanistan. To make sure that this support can continue to flow, OFAC has issued six General Licenses (GLs) — 14, 15, 16, 17, 18, 19, and 20 — under the Global Terrorism Sanctions Regulations, 31 CFR part 594 (GTSR), the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597 (FTOSR), and Executive Order (E.O.) 13224, as amended. These GLs authorize certain transactions and activities that are ordinarily incident and necessary to allow for the continued flow of humanitarian assistance and other activities to support the people of Afghanistan and that involve the Taliban and the Haqqani Network, as explained in greater detail below. The Taliban and Haqqani Network are designated as Specially Designated Global Terrorists (SDGTs) under E.O. 13224, and the Haqqani Network is also designated as a Foreign Terrorist Organization under section 219 of the Immigration and Nationality Act. However, there are no OFAC-administered sanctions that prohibit the export or reexport of goods or services to Afghanistan, moving or sending money into and out of Afghanistan, or activities in Afghanistan, provided that such transactions or activities do not involve sanctioned individuals, entities, or property in which sanctioned individuals and entities have an interest. In addition, as described below, OFAC has issued seven Afghanistan-related GLs to authorize certain transactions involving the Taliban, the Haqqani Network, and, in the case of GL 20, blocked individuals who are in leadership roles of governing institutions in Afghanistan. While the United States is working to facilitate financial flows that benefit the Afghan people, Treasury recognizes that the Afghan people will continue to face grave challenges, exacerbated by donor and private sector flight sparked by the Taliban’s takeover, longstanding dependences on foreign aid, drought, structural macroeconomic issues, and the ongoing COVID-19 pandemic. === PAGE BREAK === Afghanistan-Related OFAC General Licenses The following GLs are issued by OFAC related to humanitarian assistance, other support, and trade with Afghanistan: • All transactions involving Afghanistan or governing institutions in Afghanistan: GL 20, “Authorizing Transactions Involving Afghanistan or Governing Institutions in Afghanistan,” authorizes all transactions involving Afghanistan or governing institutions in Afghanistan, subject to certain conditions. The authorization in Afghanistan-related GL 20 may overlap with the authorizations in Treasury’s other Afghanistan-related GLs 14, 15, 16, 17, 18, and 19 (described in detail below). Where appropriate, U.S. persons may rely on the broader authorization in GL 20 instead of the authorizations in GLs 14, 15, 16, 17, 18, and 19. As with all OFAC GLs, GLs 14, 15, 16, 17, 18, 19, and 20 are “self-executing,” meaning that persons who determine that such activities are ordinarily incident and necessary to their authorized activity within the scope of the GL may proceed without further assurance from OFAC. • Humanitarian Activities in Afghanistan: GL 14, “Authorizing Humanitarian Activities in Afghanistan,” authorizes all transactions involving the Taliban or the Haqqani Network, or any entity in which the Taliban or the Haqqani Network owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, prohibited by the GTSR, the FTOSR, or E.O. 13224, as amended, that are ordinarily incident and necessary to the provision of humanitarian assistance to Afghanistan or other activities that support basic human needs in Afghanistan by the following entities and their employees, grantees, contractors, or other persons acting on their behalf, subject to certain conditions: o The United States Government; o Nongovernmental organizations; o The United Nations, including its Programmes, Funds, and Other Entities and Bodies, as well as its Specialized Agencies and Related Organizations; o The International Centre for Settlement of Investment Disputes (ICSID) and the Multilateral Investment Guarantee Agency (MIGA); o The African Development Bank Group, the Asian Development Bank, the European Bank for Reconstruction and Development, and the Inter-American Development Bank Group (IDB Group), including any fund entity administered or established by any of the foregoing; o The International Committee of the Red Cross and the International Federation of Red Cross and Red Crescent Societies; and 2 === PAGE BREAK === o The Islamic Development Bank. • Agricultural Commodities, Medicine, and Medical Devices: GL 15, “Transactions Related to the Exportation or Reexportation of Agricultural Commodities, Medicine, Medical Devices, Replacement Parts and Components, or Software Updates,” authorizes all transactions involving the Taliban or the Haqqani Network, or any entity in which the Taliban or the Haqqani Network owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, prohibited by the GTSR, the FTOSR, or E.O. 13224, as amended, that are 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 Afghanistan, or to persons in third countries purchasing specifically for resale to Afghanistan, subject to certain conditions. • Personal Remittances: GL 16, “Authorizing Noncommercial, Personal Remittances to Afghanistan,” authorizes all transactions involving the Taliban or the Haqqani Network, or any entity in which the Taliban or the Haqqani Network owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, prohibited by the GTSR, the FTOSR, or E.O. 13224, as amended, that are ordinarily incident and necessary to the transfer of noncommercial, personal remittances to Afghanistan, including through Afghan depository institutions, subject to certain conditions. As noted in OFAC FAQ 949, transactions that are ordinarily incident and necessary to give effect to the activities authorized in GL 16, including clearing, settlement, and transfers through, to, or otherwise involving privately owned and state-owned Afghan depository institutions, are also authorized pursuant to GL 16. • U.S. Government Business: GL 17, “Official Business of the United States Government,” authorizes all transactions and activities involving the Taliban or the Haqqani Network, or any entity in which the Taliban or the Haqqani Network owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, prohibited by the GTSR, the FTOSR, or E.O. 13224, as amended, that are for the conduct of the official business of the United States Government by employees, grantees, or contractors thereof, subject to certain conditions. • International Organizations: GL 18, “Official Activities of Certain International Organizations and Other International Entities,” authorizes all transactions and activities involving the Taliban or the Haqqani Network, or any entity in which the Taliban or the Haqqani Network owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, prohibited by the GTSR, the FTOSR, or E.O. 13224, as amended, that are for the conduct of the official business of the following entities by employees, grantees, or contractors thereof, subject to certain conditions: o The United Nations, including its Programmes, Funds, and Other Entities and Bodies, as well as its Specialized Agencies and Related Organizations; 3 === PAGE BREAK === o The International Centre for Settlement of Investment Disputes (ICSID) and the Multilateral Investment Guarantee Agency (MIGA); o The African Development Bank Group, the Asian Development Bank, the European Bank for Reconstruction and Development, and the Inter-American Development Bank Group (IDB Group), including any fund entity administered or established by any of the foregoing; o The International Committee of the Red Cross and the International Federation of Red Cross and Red Crescent Societies; and o The Islamic Development Bank. • Nongovernmental Organizations: GL 19, “Certain Transactions in Support of Nongovernmental Organizations’ Activities in Afghanistan,” authorizes all transactions and activities involving the Taliban or the Haqqani Network, or any entity in which the Taliban or the Haqqani Network owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, prohibited by the GTSR, the FTOSR, or E.O. 13224, as amended, that are ordinarily incident and necessary to activities described below by NGOs, subject to certain conditions: o Activities to support humanitarian projects to meet basic human needs in Afghanistan, including drought and flood relief; food, nutrition, and medicine distribution; the provision of health services; assistance for vulnerable or displaced populations, including individuals with disabilities, the elderly, and survivors of sexual- and gender-based violence; and environmental programs; o Activities to support the following in Afghanistan: rule of law, citizen participation, government accountability and transparency, human rights and fundamental freedoms, access to information, and civil society development projects; o Activities to support education in Afghanistan, including combating illiteracy, increasing access to education, international exchanges, and assisting education reform projects; o Activities to support non-commercial development projects directly benefitting the Afghan people, including those related to health, food security, and water and sanitation; and o Activities to support environmental and natural resource protection in Afghanistan, including the preservation and protection of threatened or endangered species, responsible and transparent management of natural resources, and the remediation of pollution or other environmental damage. 4 === PAGE BREAK === In all cases, authorized transactions and activities must comply with the terms and conditions set forth in the applicable GL. Notably, the GLs listed above explicitly do not authorize financial transfers to the Taliban or the Haqqani Network, other than for the purpose of effecting the payment of taxes, fees, or import duties, or the purchase or receipt of permits, licenses, or public utility services related to the activities specified. GL 20, specifically, does not authorize financial transfers to the Taliban, the Haqqani Network, any entity in which the Taliban or the Haqqani Network owns, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, or any blocked individual who is in a leadership role of a governing institution in Afghanistan, other than for the purpose of effecting the payment of taxes, fees, or import duties, or the purchase or receipt of permits, licenses, or public utility services, provided that such payments do not relate to luxury items or services. In addition, these GLs do not relieve any person from compliance with other U.S. federal laws or requirements of other federal agencies, or from applicable international obligations. These GLs also help implement adopted resolution UNSCR 2615 (2021), which authorizes humanitarian assistance and other activities that support basic human needs as those terms are understood by the United Nations Security Council, as well as the processing and payment of funds, other financial assets or economic resources, and the provision of goods and services necessary to ensure the timely delivery of such assistance or to support such activities. Specifically, UNSCR 2615 (2021) was intended to cover activities contemplated in the United Nations’ Transitional Engagement Framework (TEF) for Afghanistan, such as providing life- saving assistance; sustaining essential services; and preserving social investments and community-level systems essential to meeting basic human needs. Afghanistan-Related Frequently Asked Questions (FAQs) The following FAQs provide information on the provision of humanitarian assistance and certain other activities in support of the Afghan people: FAQ 928 – Guidance on U.S. sanctions on the Taliban and the Haqqani Network and humanitarian assistance to Afghanistan FAQ 929 – Guidance on activities included in “Humanitarian Assistance to Afghanistan” and “Other Activities to Support Basic Human Needs in Afghanistan” FAQ 930 – Guidance on U.S. sanctions on the Taliban and the Haqqani Network and exportation or reexportation of agricultural commodities, medicine, and medical devices to Afghanistan FAQ 931 – Guidance related to non-U.S. persons engaging in activities authorized under GLs 14, 15, 16, 17, 18, and 19 FAQ 949 – Guidance on U.S. sanctions on the Taliban and the sending of personal, non- commercial remittances to Afghanistan 5 === PAGE BREAK === FAQ 950 – Guidance on organizations included within the United Nations’ “Programmes, Funds, and Other Entities and Bodies, as well as its Specialized Agencies and Related Organizations,” for purposes of GL 18 FAQ 951 – Guidance on U.S. sanctions and Afghanistan FAQ 952 – Guidance on identifying Specially Designated Global Terrorists (SDGTs) when operating in Afghanistan FAQ 953 – Guidance on U.S. sanctions on the Taliban and the Haqqani Network and moving money in and out of Afghanistan FAQ 954 – Guidance on transactions and activities considered “Ordinarily Incident and Necessary” to activities authorized under GLs 14, 15, and 19 FAQ 955 – Guidance on GLs 17, 18, and 19 and the UN Security Council’s 1988 (Taliban) sanctions regime FAQ 957 – Guidance on processing transactions related to shipping food to Afghanistan FAQ 958 – Guidance on authorized transactions with the Taliban and the Haqqani Network FAQ 959 – Guidance on support to public hospitals in Afghanistan FAQ 960 – Guidance on direct payments to Afghan teachers and healthcare workers FAQ 961 – Guidance on support to municipal water systems in Afghanistan FAQ 962 – Guidance on banks’ processing of transactions related to activities authorized by general licenses FAQ 963 – Guidance on humanitarian cash shipments to Afghanistan FAQ 991 – Guidance on why Treasury issued GL 20 FAQ 992 – Guidance on examples of activities authorized by GL 20 FAQ 993 – Guidance on governing institutions in Afghanistan led by blocked individuals FAQ 994 – Guidance on what are considered luxury items and services for the purposes of GL 20 FAQ 995 – Guidance on financial transfers to governing institutions and state-owned and - controlled companies in Afghanistan 6 === PAGE BREAK === FAQ 996 – Guidance on the scope of GL 20 vs. GLs 14-19 FAQ 997 – Guidance on whether the United States has lifted sanctions on the Taliban and the Haqqani Network Additional 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 and other requests for guidance that are related to humanitarian activity. Please see OFAC’s License Application Page for additional details regarding the specific licensing process. Additional Information If you have additional questions, we encourage you to contact the OFAC Compliance Hotline at 1-800-540-6322 or email [email protected]. As with specific license requests, OFAC prioritizes answering questions that are related to humanitarian activity. 7 === PAGE BREAK ===

DEPARTMENT OF THE TREASURY WASHINGTON, D.C. 20220 OFFICE OF FOREIGN ASSETS CONTROL GUIDANCE ON THE RELEASE OF LIMITED AMOUNTS OF BLOCKED FUNDS FOR PAYMENT OF LEGAL FEES AND COSTS INCURRED IN CHALLENGING THE BLOCKING OF U.S. PERSONS IN ADMINISTRATIVE OR CIVIL PROCEEDINGS This policy provides for the issuance ofspecific licenses, on a case-by-case basis, to authorize the release of a limited amount of blocked funds for the payment of legal fees and costs incurred in seeking administrative reconsideration or judicial review ofthe designation ofa U.S. person or the u.s. blocking ofthe property and interests in property ofa person under the authority ofExecutive orders and regulations administered by OFAC (any such U.S. person hereinafter referred to as a "Blocked Party"), where alternative funding sources are not available. Pursuant to this policy, the blocked funds from which payment is sought must be legally and beneficially owned by the Blocked Party. This policy is aimed at enhancing the ability of a Blocked Party that lacks alternative access to funds to acquire legal representation in connection with its designation or the blocking of its property and interests in property. This policy is not intended to ensure complete compensation to counsel. Limitations on the amount offunds released to a Blocked Party are necessary to preserve the President's authority and leverage in the conduct offoreign policy. This policy is separate from, but complementary to, OFAC's policies allowing for the issuance ofspecific licenses providing for a Blocked Party to receive fresh funds from unblocked sources outside the United States and to raise funds in the United States through an authorized legal defense fund. Part I: Designated or Blocked Party Requirements The new policy includes a number ofparameters. To be considered for a specific license, a Blocked Party must satisfy the following requirements: • a Blocked Party must be designated, or its property and interests in property blocked or blocked pending investigation, under the authority of Executive orders and regulations administered by OFAC; • a Blocked Party must be a U.S. person, as defined in the relevant Executive orders and regulations administered by OFAC; • a Blocked Party must be the legal and beneficial owner of the blocked funds from which payment is sought to be made; and July23, 2010 === PAGE BREAK === • the legal fees and costs for which reimbursement is sought must have been incurred in seeking administrative reconsideration orjudicial review ofthe Blocked Party's designation, blocking, or blocking pending investigation. A specific license applicant will not be eligible for a license for payment of legal fees and costs from blocked funds under this policy ifany ofthese requirements is not met. Part II: Licensing Requirements To enable OFAC to make a licensing determination, a Blocked Party and its counsel must provide the following: • evidence or a certification that the Blocked Party is a U.S. person as defined in the relevant OFAC regulations and the Executive orders under which the Blocked Party was designated or blocked; • an itemized statement of the amounts already paid for legal representation and associated costs to date, including the source(s) of payment (e.g., a legal defense fund or a source outside the United States), whether paid by or on behalfofthe Blocked Party; • a letter from the Blocked Party requesting that the legal fees and costs for a particular attorney or attorneys be paid from the Blocked Party's blocked funds, identifying the specific blocked funds from which payment is requested to be made, and providing the name and address of the bank holding the funds, the account number(s), and the name and telephone number ofa contact person at the bank; • a certification, signed by the Blocked Party and its counsel under penalty ofpeljury, that: o the Blocked Party is the legal and beneficial owner ofthe blocked funds; o no other person has a property interest in the blocked funds and the funds do not serve as security for other obligations ofthe Blocked Party; o the Blocked Party has no assets, property, or economic resources ofany type outside the United States; and o the Blocked Party has fully reported or caused to be reported, pursuant to 31 C.F.R. § 501.603, any of its property or interests in property blocked pursuant to 31 C.F.R. Chapter V; • an itemized statement of the hourly rate and number of hours billed per attorney for legal services directly related to the request for administrative reconsideration or judicial review of the designation or blocking, divided by each phase of the case (administrative proceedings before OFAC, district court, and appellate court); and • an itemized statement and description of costs incurred in seeking administrative reconsideration or judicial review of the designation or blocking, divided by each phase of the case. OFAC may request that the Blocked Party and its counsel furnish additional information as necessary. 2 === PAGE BREAK === An application requesting a specific license authorizing the release of blocked funds under this policy may be submitted at each stage ofthe administrative proceedings or litigation, either (i) when the licensable fees and costs incurred for that stage ofthe proceedings or litigation have reached the applicable cap; or (ii) at the end ofthat stage ofthe proceedings or litigation. Any licenses issued pursuant to this policy will authorize payment from blocked funds directly to the attorney or attorneys representing the Blocked Party. Part III: Monetary Limitations The monetary limitations of this policy are modeled generally on the attorney compensation provisions of the Criminal Justice Act (CJA) and the Equal Access to Justice Act (EAJA). Specifically, in a manner similar to the EAJA, the payment oflegal fees from blocked funds may be licensed at a rate not to exceed $125 per hour, up to a cap set for each stage of the administrative proceedings or litigation. OFAC anticipates tracking the EAJA hourly rate if it changes in the future. With respect to applications submitted by a designated Blocked Party, the policy incorporates fee caps per proceeding, as does the CJA, and limits the amount of licensable fees to $14,000 for administrative proceedings; $14,000 for district court litigation; and $10,000 for appellate court litigation.I In extraordinary cases, such as cases involving lengthy or complex proceedings (e.g., may include cases lasting more than a year or with multiple patties whose designation or blocking resulted from a substantially similar administrative record or set of facts), the maximum fees allowed could be doubled for each stage. Thus, in these cases, counsel might be licensed up to a total of$28,000 for administrative proceedings; $28,000 for district court litigation; and $20,000 for appellate court litigation. These overall monetary caps are calculated based on two attorneys per case, but a Blocked Party may choose to apportion the maximum allotments between a greater or smaller number oflegal representatives. In addition to legal fees, certain legal costs ofa designated Blocked Party may be licensed for payment from blocked funds, up to a cap of$15,000; this cap applies to costs incurred by all attorneys during the course of administrative proceedings and litigation? The overall fee capsare based on the calculations of$7,000 perattorney, for up to two attorneys, for administrative proceedings; $7,000 perattorney, for up to two attorneys, for district court litigation; and $5,000 per attorney, for up to two attorneys, for appellate court litigation. 2 As ofJuly 23, 2010, the policy's overall fee and costcaps described in Pat111I do not apply to applications submitted byaBlocked Party who has not been designated but whose property and interests in property have been "blocked pending investigation." This revision to the policyappliesonly to pendingand future licensingapplications submitted pursuant to this policyand will not be applied retroactively to persons whose propertyand interests in property previously were blocked pending investigation but who are no longer in that status. The hourly fee cap of $125 will continue to be applied to such applications. The basis for this revision to the policy is twofold. First, the decision to block aparty pending investigation is preliminary, because when OFAC blocks the propertyofadesignation target duringthe pendencyofan investigation, OFAC is in the process ofdetermining whetheraparty meetscertain designation criteria set forth in an Executiveorder for posingaspecific threat to U.S. interests. Second, ablocking pending investigation by OFAC is typicallyofashorter duration than adesignation. Though the length oftime that aparty may be blocked pending investigation will depend on the amount oftime needed to completethe investigation, blocked assets are less likely to bedepleted given the frequently shorterduration. 3 === PAGE BREAK === As a prerequisite for receiving a specific license, a Blocked Party or its counsel must provide an itemized statement ofthe amounts already paid for legal representation and costs to date, including the source(s) of payment, whether paid by or on behalfofthe Blocked Party, as set forth in Part II above. In processing applications for specific licenses authorizing the release of blocked funds, OFAC will reduce the applicable caps on legal fees and costs payable from blocked funds by any amounts previously received from either fresh funds or a legal defense fund. Should additional fresh funds or legal defense funds be received after blocked funds are licensed and used for payment oflegal fees and/or costs, then such additional funds must first be deposited into a blocked account until the amount previously unblocked is restored. Any remaining funds may then be applied to legal fees and/or costs. 4 === PAGE BREAK ===

DEPARTMENT OF THE TREASURY WASHINGTON, D.C. 20220 August 13,2014 REVISED GUIDANCE ON ENTITIES OWNED BY PERSONS WHOSE PROPERTY AND INTERESTS IN PROPERTY ARE BLOCKED This guidance responds to inquiries received by the Department of the Treasury's Office of Foreign Assets Control (OFAC) relating to the status of entities owned by individuals or entities designated under Executive orders and regulations administered by OF AC. This document sets forth new guidance with respect to entities owned 50 percent or more in the aggregate by more than one blocked person. Property blocked pursuant to an Executive order or regulations administered by OF AC is broadly defined to include any property or interest in property, tangible or intangible, including present, future or contingent interests. A property interest subject to blocking includes interests of any nature whatsoever, direct or indirect. Persons whose property and interests in property are blocked pursuant to an Executive order or regulations administered by OFAC (blocked persons) are considered to have an interest in all property and interests in property of an entity in which such blocked persons own, whether individually or in the aggregate, directly or indirectly, a 50 percent or greater interest. Consequently, any entity owned in the aggregate, directly or indirectly, 50 percent or more by one or more blocked persons is itself considered to be a blocked person. The property and interests in property of such an entity are blocked regardless of whether the entity itself is listed in the annex to an Executive order or otherwise placed on OFAC's list of Specially Designated Nationals ("SDNs"). Accordingly, a U.S. person generally may not engage in any transactions with such an entity, unless authorized by OF AC. In certain OF AC sanctions programs (e.g., Cuba and Sudan), there is a broader category of entities whose property and interests in property are blocked based on, for example, ownership or control. U.S. persons are advised to act with caution when considering a transaction with a non-blocked entity in which one or more blocked persons has a significant ownership interest that is less than 50 percent or which one or more blocked persons may control by means other than a majority ownership interest. Such entities may be the subject of future designation or enforcement action by OFAC. Furthermore, a U.S. person may not procure goods, services, or technology from, or engage in transactions with, a blocked person directly or indirectly (including through a third party intermediary). OFAC will incorporate this guidance as it issues regulations implementing new sanctions programs. In addition, OF AC expects to amend regulations implementing existing sanctions programs to reflect this guidance. === PAGE BREAK ===