The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) today issued two general licenses (E and F) related to certain humanitarian and athletic activity involving Iran. This is but one more step in the direction of the Administration’s de facto policy of loosening restrictions on lower level, less sensitive activities (to therefore presumably ratchet up pressure on more important issues).
General License E addresses humanitarian matters. Specifically, these include certain activities related to:
- “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” (note exporting food, clothing and medicine towards the relief of human suffering was previously allowed).
- Certain non-commercial reconstruction following a natural disaster
- Certain sponsorship of conferences on human rights and related matters as well as surveying, etc.
- Related transfers of funds related to NGOs up to $500,000 in an aggregate 12-month period
Note the reporting requirements. Indeed, NGOs must report certain activities to OFAC on a quarterly basis. Obviously, blocked entities are still generally off limits.
General License F is also interesting. It covers athletic activities, following on the coattails of Iranian tennis referee Adel Borghei’s case (see the immediately previous entry on this blog and the article in last week’s New York Times). If you remember, Mr. Borghei’s offer to referee at the U.S. Open was rescinded until another lawyer and I managed to secure an OFAC license for him to provide services there.
This new general license (quite possibly at least partially the result of Borghei’s case) would fix this, by allowing U.S. persons to provide certain athletic services in Iran and vice versa, whether the event is amateur or professional. It specifically includes, among other things, an authorization to engage in “activities related to exhibition matches and events, the sponsorship of players, coaching, refereeing, and training.” This can be a huge issue given the significant number of Iranian-American coaches and refs who now may be recruited to provide services in Iran in areas such as soccer. The sponsorship will also be interesting as it could lead to U.S. sponsoring of Iranian athletes.