General license
Since the August 11th earthquake in northwestern Iran, non-governmental organizations (NGOs) have been assisting in the relief efforts.
To assist their efforts, OFAC issued a temporary general license today, which authorizes, for the next 45 days, NGOs with 501(c)(3) status to collect funds to be used in direct support of humanitarian relief and reconstruction activities in response to the earthquake.
Under the general license—which will remain in effect until October 5, 2012—an NGO can transfer funds up to $300,000 during the 45-day period to Iran to be used for humanitarian relief and reconstruction activities related to the earthquake response.
NGOs interested in transferring more than $300,000 during the 45-day period may apply for a specific license.
The general license specifically forbids any dealings or involvement with individuals or entities designated for support for the proliferation of weapons of mass destruction or terrorism, such as the Islamic Revolutionary Guard Corps (IRGC), as listed on the Treasury Department’s List of Specially Designated Nationals and Blocked Persons (SDN List).
Food and medicine donations
Donations of food and medicine to Iran already do not require a license from OFAC. These donations, when intended to be used to relieve human suffering, are exempt from the sanctions on trade with Iran, as long as the donations are not being sent to the government of Iran or any Iranian individual or entity on the Treasury Department’s SDN List.
Today’s OFAC release concludes that for all practical purposes, such donations to the Iranian people, including transactions needed to ship permissible donations, can occur without a specific license from OFAC.
For more information, contact:
Rick Speizman, National Partner-In-Charge, KPMG’s Exempt Organizations Tax Practice (ExoTax)
+1 (202) 533-3084