General License E of ITSR

General License E, authorizing certain services in support of non-governmental organization activities in Iran. This general license encompasses several authorizations that non-governmental organizations are permitted to do within set restrictions for the benefit of civilians in Iran.

Previously, the general license contents and authorizations were authorized after humanitarian or natural disasters occurred in Iran for a certain period of time and after several events, General License E allowed, in 2013, for continuous authorization when the activity of a non-governmental organization in the United States which fit under the scope of General License E. To learn more about general licenses for Iran sanctions, contact a distinguished OFAC lawyer right away.

What Does General License E of ITSR Mean for Exporting Services?

General License E states that NGOs are authorized to export or re-export services to Iran for non-profit activities designed to benefit the Iranian people. This includes humanitarian projects, provision of donated health-related services, orphanages, natural disasters, and standards of charitable activity.

It also includes non-commercial reconstruction projects in response to natural disasters which are limited to two years after the natural disaster, as well as activities related to environmental and wildlife conservation projects in Iran, and activities related to human rights and democracy building.

These broad authorizations are limited in scope of a single non-governmental organization not exceeding $500,000 of over a 12-month period of funds transferred to Iran. NGOs must also submit quarterly reports, detailing the parties and persons and entities involved in these transactions and services.

Defining General License Exclusions

This General License also specifically excludes anything outside of a scope of the license as well as any activity that furthers Iran in military or industrial infrastructure potentially relating to the energy automobile shipping and shipbuilding sectors of Iran. This license is updated and released in September 10, 2014. And then after the recent earthquake in Western Iran, OFAC released frequently asked questions and responded to humanitarian assistance for the November 12 earthquake in Iran.

FAQs Related to General License E of ITSR

The frequently asked question number 549 reiterated that General License E permits non-governmental organizations to transfer up to half a million dollars per year in support of humanitarian and disaster relief services and funds transfers. It notes, specifically, that only non-governmental organizations established or have US jurisdiction and are permitted to work under the authorization of General License E and therefore, US persons and US individuals, specifically, are not able to, on their own, transfer a fund that provides services without being under the umbrella of a non-governmental organization.

Types of Unauthorized Transactions

There are no specifics on what is not authorized but essentially, anything outside of the scope of the General License that is in place which could be anything relating to charities and the charitable actions that are outside of the scope of what is authorized in General License E. This primarily relates to relief services related to natural disasters and donating health-related services as well as distributing donated items like food, clothing, and medicine in terms of suffering in Iran. A standard charitable activity outside of a disaster relief scope is going to require a specific license and that means direct authorization from OFAC prior to engaging in any transactions or funds transfers.

In the case of humanitarian activity related to disaster relief, only non-governmental organizations that are permitted to use General License E, with all conditions of restrictions in General License E and General License E permits US financial institutions to transfer funds to Iran to assist friends or family members so long as the transfer works or meets the requirements of the other provisions in the IPSR.