On Oct. 22, 2012, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a statement saying it will expedite its decision making process on license applications from American entities engaging in “certain human rights, humanitarian, and democracy-related activities with respect to Iran.” OFAC also announced it had made changes to the Iranian Transactions and Sanctions Regulations (31 C.F.R. part 560) to allow the exportation of medical supplies into Iran without applying for a specific license. The list of permitted medical supplies is available here. This action comes just days after OFAC extended the General License allowing non-governmental organizations (NGOs) to raise and send funds to Iran specifically for humanitarian relief efforts related to the August earthquakes.
An FAQ about the statement on treasury’s website included this Q &A about the expedited license procedures:
“What does the Statement of Licensing Procedure on Support of Human Rights-, Humanitarian-, and Democracy-Related Activities with Respect to Iran do?
The Statement of Licensing Procedure reflects procedures established pursuant to section 413 of the TRA. These procedures stipulate that, as of the effective date of the TRA, license determinations for complete requests for authorization under this policy shall be made not later than 90 days after receipt by OFAC, with certain exceptions. The Statement of Licensing Policy applies to applications submitted by the following categories of U.S. persons seeking to engage in certain human rights-, humanitarian-, and democracy-related activities with respect to Iran: (1) entities receiving funds from the Department of State to engage in the proposed activity; (2) the Broadcasting Board of Governors; and (3) other appropriate agencies of the United States Government. The ITSR also include separate statements of licensing policy related to the sharing of information over the Internet in Iran and the support of democracy and human rights in Iran and academic and cultural exchange programs. (emphasis added)
The FAQ also includes a question about remittances and said activities involving journalism, educational activities (including certain exchange programs), and participation in conferences in Iran, were now permitted under newly authorized general licenses.
With many Iranian hospitals experiencing massive shortfalls in supplies, the easing of restrictions is welcome news. However, some analysts say the move is not to be seen as a “loosening” of sanctions. According to Al-Monitor, “by removing the stories of Iranian children suffering due to medicinal shortages from the headlines, the administration may be hoping to strengthen the economic noose surrounding Iran and perhaps pave the way for more restrictive measures.”