How to legally send humanitarian aid to sanctioned countries: Iran, Syria, and Venezuela
Sending humanitarian aid to sanctioned countries is a task that requires legal assistance and a strategic approach. Even if the shipment consists of medicines and food, attempting to cross borders without complying with sanction laws can result in the shipment being blocked, criminal prosecution, and reputational losses. Many are unaware that sanction regimes allow exceptions for humanitarian purposes, but only with strict adherence to procedures and the presence of appropriate licenses. This is especially relevant for organizations working with international donors, logistics operators, and banks. An error in one document—and the entire mission is at risk.
Our legal team specializes in the lawful organization of humanitarian deliveries to Iran, Syria, and Venezuela. Experienced specialists ensure a comprehensive analysis of applicable sanctions regimes, obtaining the necessary licenses from OFAC and other regulators, thorough due diligence of counterparties for compliance with AML/CTF requirements and SDN lists, support for logistics and banking operations, and preparation of documents for customs and regulatory authorities. We work with NGOs, international organizations, companies, and individuals.
What is OFAC and why is it important for humanitarian aid?
Office of Foreign Assets Control is the Office for the Control of Foreign Assets of the U.S. Department of the Treasury. It is responsible for implementing U.S. economic and trade sanctions against states, organizations, and individuals involved in terrorism, human rights violations, financing weapons of mass destruction, money laundering, and other threats to national security.
The jurisdiction of OFAC extends not only to American companies and U.S. citizens. All entities using U.S. dollars, interacting with American banks, or having any American connection (involvement of an American shareholder, American software, infrastructure, email servers, etc.) are required to comply with OFAC regulations. Even a charity registered in Europe or the Middle East can be subject to sanctions control if it conducts transactions in dollars or uses the American financial system.
OFAC sanctions do not always prohibit humanitarian aid but require compliance with special procedures, obtaining licenses, and arranging exemptions. For example, sending medicines, food, and other essential goods to Iran, Syria, or Venezuela is theoretically possible but only with the appropriate authorization from OFAC and compliance with all conditions, including verifying that the recipient is not on the sanctions lists.
Ignoring these requirements can have serious consequences. OFAC actively investigates violations and often imposes multimillion-dollar fines, even if the violation was unintentional. In some cases, criminal charges may be initiated.
General Principles of OFAC Humanitarian Exceptions
OFAC recognizes that sanctions should not hinder saving lives and meeting the basic needs of populations in crisis zones. Therefore, most sanctions programs include mechanisms that allow:
- To supply food and agricultural products;
- Send medications, medical equipment, and hygiene products;
- Finance projects in water supply, sanitation, and other critically important sectors;
- Support the activities of international humanitarian organizations.
However, for this, strict compliance with the established OFAC rules is necessary. Even a humanitarian mission may be deemed to violate sanctions if it is not properly documented.
General Licenses are pre-issued authorizations that allow certain categories of transactions to occur without the need to apply for individual permission. Such licenses are published on the official OFAC website and apply to all participants who meet the conditions. GLs are the fastest and most convenient way to operate legally in a sanctions environment. However, they require strict compliance with the conditions: the list of permitted goods, counterparties, delivery routes, payment methods.
If the operation does not fall under the General License, obtaining a Specific License will be required. This is an individual authorization issued by OFAC based on a specific request. The application process includes a detailed description of the operation, evidence of its humanitarian nature, identification of all parties and routes, and justification for the absence of risk in financing sanctioned persons. The issuance of a Specific License may take from several weeks to several months. However, without it, conducting the operation will be considered a violation of U.S. sanctions law, even if the goal was humanitarian aid.
Errors in interpreting license conditions, choosing an inappropriate aid recipient, or even an accidental transaction through an American bank — all of this can lead to serious consequences: from payment blockage to multimillion-dollar fines. An experienced legal consultant will help determine whether the project falls under the current General License, prepare documentation for submitting an application for a Specific License, check counterparties for inclusion in sanctions lists, and develop a transparent and secure logistical and financial scheme.
SDN OFAC List
Specially Designated Nationals and Blocked Persons List is an official list of individuals, companies, organizations, and vessels whose assets are blocked by OFAC, and any activity with them is prohibited for U.S. citizens and companies. Inclusion in the SDN List means complete financial isolation within U.S. jurisdiction and high sanctions risks even for third parties that come into contact with these individuals.
The SDN List is a key tool of U.S. sanctions policy. It covers individuals and entities associated with terrorism, weapons proliferation, human rights violations, money laundering, cybercrimes, and other threats. All banks, financial institutions, suppliers, and charitable organizations are required to check their counterparties against this list before initiating any transaction.
Even if you act with humanitarian purposes, assistance cannot be provided directly to individuals or entities from the SDN List without special permission from OFAC. Violating this rule may result in severe fines, asset freezes, and criminal liability. That is why, before any foreign economic or charitable activity, it is important to conduct a thorough check of beneficiaries and routes to ensure there are no overlaps with OFAC lists.
How to send humanitarian aid to Iran
The US sanctions policy towards Iran is one of the strictest in the world and is regulated by a number of legal acts, including the Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA), the Iran Threat Reduction and Syria Human Rights Act (ITRA), and Executive Orders 13846 and 13902. These laws restrict almost all economic interactions with Iranian individuals and entities, especially in the fields of energy, finance, and technology.
The key tool for sending humanitarian aid is General Licenses, which automatically allow the export of certain humanitarian goods without the need to obtain individual permission. In particular, this applies to medicines, medical equipment, food, agricultural products, and certain software solutions. Additionally, shipments must be clearly documented, and in case of doubt, it is recommended to submit a request for a Specific License to avoid violating the sanctions regime.
OFAC procedures and requirements for Iran: licenses and reporting
The first step is to analyze the operation itself: what goods, services, or technologies you plan to supply, who the end recipient is, and what the transaction route is. If the operation does not fall within the framework of GL, it is necessary to obtain a Specific License. The issuance of an SL requires a formal application to OFAC with a complete set of documents. The application is submitted through the electronic system OFAC License Application and must include:
- Detailed description of the operation, including participants, goal, scope, timelines;
- Contracts, invoices, commercial offers, confirming the nature of the transaction;
- Justification for why the deal does not fall under GL and why it should be allowed;
- Measures of control to ensure that the supply does not fall under sanctions (due diligence);
- Information about the financial channels used, suppliers, intermediaries.
The application review period may vary from 2 to 6 months, depending on the complexity of the case and the volume of information. It is important for the application to be as clear, detailed, and legally substantiated as possible; otherwise, OFAC may request additional information or deny it.
Even if the operation is conducted based on a General License, companies and individuals are expected to adhere to transparency and accountability:
- Maintaining complete documentation for each operation: invoices, payment documents, correspondence, identification of parties;
- Mandatory submission of a notification to OFAC regarding the completed transaction;
- Storage of all documents for at least 5 years in case of an audit or a request from regulators.
If the operation is carried out under a Specific License, after its completion you must submit a report to OFAC on the execution of the transaction, confirm that the conditions of the license were met, and also provide explanations if deviations or difficulties arose.
OFAC and sending humanitarian aid to Syria
The main legal basis for the sanctions regime against Syria is the Caesar Syria Civilian Protection Act (Caesar Act), which came into force in June 2020. This law has significantly complicated any economic and logistical operations due to strict restrictions on interactions with government and affiliated structures in Syria. OFAC oversees the sanctions regime against Syria based on Executive Orders 13572, 13573, 13582, and 13894. The sanctions concern:
- State institutions of Syria and companies associated with them;
- Financial institutions serving the interests of the Syrian regime;
- Individuals and legal entities providing material, technological, and financial support to the government of Bashar al-Assad;
- Oil and gas sector, infrastructure projects, and military supplies.
Caesar Syria Civilian Protection Act strengthened the effect of previous decrees, focusing attention on secondary sanctions. Even non-American organizations and individuals may fall under sanctions if they:
- Participate in the restoration of infrastructure controlled by the Syrian government;
- Supply building materials, equipment, or services that can be used to strengthen the regime;
- Conduct financial transactions with individuals from the SDN list.
Despite the overall sanctions regime, OFAC recognizes the importance of humanitarian support for the civilian population of Syria. For this purpose, General Licenses are provided, allowing:
- Export food products, medicines, and essential items;
- Provide medical assistance and technical support in the field of healthcare;
- Ensure communication (supply of software and communication devices);
- Conduct the activities of international humanitarian organizations accredited by the UN and other supranational structures.
However, even with the presence of a General License, it is important to conduct due diligence on recipients, avoid involvement with sanctioned individuals, document all stages of the transaction, and, if necessary, seek a Specific License if the project goes beyond the scope of standard permissions.
How to prevent OFAC violations in Syria
To avoid unintentional violation of the sanctions regime, it is necessary to implement strict compliance procedures. First and foremost, it is important to conduct mandatory screening of all counterparties — including partners, suppliers, aid recipients, transportation companies, and even local consultants. The screening should cover not only the SDN List but also Non-SDN Sanctions Lists as well as other OFAC registries.
Even if the aid is directed exclusively to the civilian population, it is not excluded that resources may indirectly end up at the disposal of sanctioned entities. This is especially relevant in cases where beneficiaries are connected to Syrian government institutions or regional organizations under sanctions. In such cases, it is recommended to contact OFAC for clarification or submit an application for a Specific License, justifying the humanitarian purpose of the operation.
Humanitarian organizations can use the General License. But it applies only to clearly defined types of activities and goods: food, medicines, sanitary products. At the slightest doubt regarding the legality of the transaction, it is necessary to suspend it and request a legal assessment. It is also necessary to maintain internal documentation that records the justification for each decision. This can play a decisive role in case of an audit.
To reduce risks, it is recommended to establish direct communication with OFAC. It also makes sense to involve legal consultants familiar with the practice of sanctions regulation, who can help conduct an audit of supply schemes and financing routes. Reliable compliance is a guarantee of lawful and efficient operation in complex jurisdictions.
Sending humanitarian aid to Venezuela
US sanctions against Venezuela are primarily aimed at the government of Nicolás Maduro, key officials, and the state oil company PDVSA.
General Licenses allow certain organizations and individuals to engage in humanitarian activities provided they meet established criteria. The export of food, agricultural products, medicines, and medical equipment intended for the civilian population is permitted. Transactions related to the provision of humanitarian aid are also allowed, as long as they do not involve interaction with sanctioned entities.
Humanitarian operations must exclude direct or indirect financing of sanctioned individuals or organizations. All parties involved in the process, including carriers, distributors, and local partners, are subject to thorough compliance screening. Even if the delivery is carried out under a license, the responsibility for violating the conditions lies entirely with the sender.
OFAC Licenses and Assistance Channels for Venezuela
OFAC emphasizes that humanitarian operations can be carried out under General Licenses, provided they are not connected with sanctioned individuals or organizations. However, many cases require individual consideration. In such cases, it is necessary to apply for a Specific License.
To minimize the risks of sanctions violations, lawyers recommend using verified channels for delivering aid (international humanitarian NGOs and UN agencies), which not only have experience working in difficult conditions but also have established compliance mechanisms, including beneficiary verification and reporting to donors. OFAC also explicitly states that the use of neutral, non-commercial structures helps reduce sanctions risks.
Common mistakes in humanitarian deliveries under sanctions
Many shipments under sanctions face the same mistakes that can be avoided with proper legal preparation. Therefore, we have compiled a checklist of common violations that deserve special attention. So, what should not be allowed in humanitarian shipments?
1. Lack of recipient verification against the SDN List
Even if you are sending medications or food products, any interaction with individuals and organizations included in the SDN list is prohibited without a special OFAC license. Many senders do not check the final recipient, especially when it comes to local contractors, warehouses, and intermediaries. Always screen all participants in the chain through an up-to-date SDN List.
2. Working with an unverified logistics provider
A logistics company may turn out to be registered in a sanctioned jurisdiction, belong to an SDN individual, or already have a history of violations. If such an intermediary is involved in delivery, the risks fall on the sender, especially if control over the cargo is transferred without proper verification. Check not only the ultimate beneficiaries but also all contractors, including logistics, storage, insurance, and finances.
3. Shipment without a license in case of a suspicious nature of the cargo
Even with a General License, a humanitarian shipment may contain dual-use goods or components that require separate authorization (for example, medical equipment with programmable elements, IT equipment, etc.). Shipment without a Specific License may be considered a violation of the sanctions regime. If in doubt about the classification of the cargo, obtain a legal opinion.
4. Insufficient documentation when using General License
General Licenses grant the right to perform certain actions but require the sender to keep supporting documents: invoices, contracts, correspondence, supply route, information about the recipient, and the origin of the goods. The absence of such documentation during an inspection may be deemed a violation. Create an internal compliance dossier for each shipment and retain it for at least 5 years.
5. Ignoring the currency channel
One of the most common mistakes is the use of the US dollar in an international transaction, even if both parties are non-American. In this case, the operation automatically falls under OFAC jurisdiction, and any violations may result in sanctions. When supplying to sanctioned countries, avoid settlements in US dollars unless the transaction is fully verified and falls under licensed exceptions.
Even one of the listed violations can not only lead to a supply blockage but also raise suspicion of sanctions evasion. OFAC actively monitors transaction and supply chains, especially in countries under humanitarian observation. Engaging legal consultants at the planning stage of supply allows not only to avoid mistakes but also to prepare a defensive strategy in advance.
Development of OFAC Compliance Program
The presence of an appropriate OFAC compliance program can help prevent sanctions violations, convincingly demonstrate to regulators that the company acted in good faith, mitigate or eliminate penalties in the case of unintentional violations.
Let us consider the key elements of an effective OFAC Compliance program:
- Risk Assessment. The first step is the analysis of business specifics and identification of risk areas: geography of operations and counterparties, currencies used, supply chain, involved financial and logistics intermediaries. Regular risk assessment allows adapting the program to the changing environment: new sanctions regimes, updates to SDN lists.
- Internal Controls. Creation and implementation of clear procedures regulating the conduct of sanctions screening, verification of partners, clients, suppliers, and employees, standards for documentation and data storage, the procedure for responding to suspicious operations. These mechanisms must be documented in a written OFAC Compliance Policy and easily accessible to all employees.
- Training and Awareness. Ignorance of the law does not exempt from responsibility. Therefore, regular training for employees is a mandatory part of the program. Training must be adapted to the risk level of a specific position, updated when sanctions legislation changes, and also documented (protocols, tests, training reports).
- Ongoing Screening & Monitoring. OFAC requires regular screening of all parties involved in the transaction: recipients and senders of funds, suppliers, carriers, warehouses, banking intermediaries, and payment system operators, as well as internal personnel. Screening must be conducted against the current OFAC lists. We recommend using automated tools with access to the latest updates and a logging function.
- Audits & Reporting. The program must include mechanisms for regular effectiveness checks: internal audits (phased, selective, thematic), channels for anonymous reporting of potential violations, protocols for incident response and interaction with lawyers. Voluntary disclosure of a violation in the presence of a program can significantly reduce or completely eliminate penalties.
Interaction with OFAC: consultations and self-disclosure
In case of uncertainty or doubts regarding the application of sanctions legislation, OFAC encourages companies and individuals to seek official clarifications (interpretive guidance). This is especially important in complex deal structures, involvement of third countries, and non-standard transactions where there is a risk of unintentional violations.
In addition, OFAC implements the Voluntary Self-Disclosure (VSD) policy. It allows organizations to independently notify the regulator about a possible violation of the sanctions regime before it becomes known from other sources. With this approach, OFAC considers the fact of self-disclosure as a mitigating factor when deciding on the imposition of penalties. In some cases, this can lead to a significant reduction in fines or even a refusal to impose them.
It is important to understand that the effectiveness of VSD directly depends on how quickly and thoroughly the organization responds to a potential violation. It is necessary to provide all available information, including the circumstances of the incident, the measures taken, as well as internal changes to prevent a recurrence of the situation.
Legal support in U.S. sanctions law
Our lawyers have deep knowledge of the OFAC regulatory framework, as well as practical experience in assisting clients with audits, inquiries, developing compliance programs, and submitting license applications.
We provide strategic consulting to companies, NGOs, and individuals on issues of sanctions compliance, interaction with banks and counterparties, operations auditing, and voluntary self-disclosure (VSD). We also protect clients’ interests in cases of potential violations and investigations by OFAC, including contesting fines and removal from sanctions lists.
If your activities are in any way connected with export, international transactions, and humanitarian aid to regions with increased sanctions risk, contact our team. We will help you act legally, safely, and with minimal risks.
FAQ
Can a US citizen send money to Syria?
Yes, but with restrictions. U.S. citizens and residents can carry out certain humanitarian transfers to Syria if they comply with the conditions of OFAC. This may require adherence to the provisions of a General License, which permits some transactions related to humanitarian activities. However, transfers benefiting individuals included in the SDN List or operations beyond the scope of the license are prohibited. Before sending funds, it is recommended to consult with sanctions law attorneys or request a Specific License from OFAC.
Who provides the most assistance to Syria?
The main humanitarian aid to Syria is provided by international organizations, including the UN (through WFP, UNHCR, and UNICEF programs), as well as major international NGOs such as the International Committee of the Red Cross (ICRC) and Médecins Sans Frontières (MSF). Significant support is also provided by individual states, including EU members, Canada, and the USA within the framework of permitted humanitarian exemptions.
Why does Venezuela need humanitarian aid?
Venezuela is experiencing a prolonged economic and political crisis, accompanied by hyperinflation, shortages of food, medicine, and critical infrastructure. Despite the presence of natural resources, sanctions imposed by the United States and other countries against Nicolás Maduro’s government and state enterprises have limited access to external financing and imports. This has worsened the humanitarian situation.
