On September 10, 2013, the Treasury Department's Office of Foreign Assets Control (OFAC) issued a general license that authorizes certain humanitarian-related activities by nongovernmental organizations (NGOs) in Iran. General License E authorizes NGOs to export or re-export services to Iran in support of the following not-for-profit humanitarian activities:

  • Activities related to humanitarian projects to meet basic human needs (the provision of donated health-related services; operation of orphanages; provision of relief services related to natural disasters; distribution of donated articles, such as food, clothing and medicine, intended to be used to relieve human suffering; and donated training related to any of these activities)
  • Non-commercial reconstruction projects in response to natural disasters for a period of up to two years
  • Environmental and wildlife conservation projects
  • Human rights and democracy building projects (the sponsorship of and attendance and training at conferences in Iran related to human rights projects, democracy building or civil society development; efforts to increase access to information and freedom of expression; and public advocacy, public policy advice, polling or surveys relating to human rights and democracy building)

Transfers of funds in support of these activities may not exceed USD$500,000 in the aggregate over a 12-month period, and NGOs must submit reports to OFAC's Licensing Division on a quarterly basis, providing information such as a description of the services, the Iranian entities or persons involved in the transaction, and the dollar amounts and beneficiaries of any transfers to Iran.

This General License does not authorize the exportation or re-exportation of services to any person whose property and interests in property are blocked, any activities in furtherance of Iranian military or industrial infrastructure or potential, or any activities relating to the Iranian energy, automobile, shipping and shipbuilding sectors.

Note that although this General License specifically targets certain activities of NGOs, the Iranian Transactions and Sanctions Regulations (ITSR) still allow for a specific license to be granted on a case-by-case basis for activities not specified in this General License. The ITSR also allows a general license for basic medical supplies (a list of which is kept on OFAC's website) and a specific license for medical devices other than basic medical supplies. Furthermore, the ITSR exempts from the prohibitions of exportation, re-exportation, sale or supply of goods, technology or services to Iran donations by U.S. persons of articles, such as food, clothing and medicine, intended to be used to relieve human suffering.

Although the United States continues to tighten financial sanctions on Iran, options do exist for the provision of humanitarian work in the country by U.S. persons.