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General Licenses for the Iran Sanctions Program

The OFAC sanctions regime regarding Iran strictly regulates international economic operations. However, general licenses allow companies and financial institutions to legally conduct transactions. Obtaining such a license provides the opportunity to operate in the sanctioned jurisdiction without the risk of fines and restrictions.
Our law firm specializes in sanctions law and international compliance. We provide an assessment of your business regarding the need for a license, full support throughout the application process with OFAC, preparation of documentation and justification for obtaining permission, consultations on compliance with the sanctions regime, and risk mitigation.

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What are the available general licenses under the Iran sanctions program?

The OFAC (Office of Foreign Assets Control) sanctions program against Iran is one of the strictest in the world, restricting financial transactions, goods exports, and international cooperation with this country. However, for certain types of activities, general licenses are provided, allowing foreign and American companies to legally conduct specific transactions without violating the sanctions regime.

General licenses are authorizing documents issued by OFAC that automatically grant the right to conduct certain transactions without requiring the submission of an individual request. These licenses help companies, international organizations, and individuals engage in legal activities in a sanctioned jurisdiction without the risk of fines or asset freezes.

As part of the sanctions program against Iran, OFAC provides various types of general licenses.

ofac sanctions

Export of goods to Iran

Although the export of most goods to Iran is prohibited, certain categories of products can be supplied to the country without individual authorization if they fall under a general license from OFAC.

It is permitted to export medicines and medical devices (excluding dual-use technologies), certain agricultural goods, as well as humanitarian aid, including food and basic medical supplies.

The export of equipment that can be used for military or nuclear purposes is prohibited. All transactions must go through authorized financial institutions not listed on the SDN list. Companies must ensure that their partners in Iran are not connected to the government or military structures.

Exceptions for the export of medical equipment to Iran

Humanitarian supplies, including medicines and medical equipment, are an exception to the sanctions regime. The supply of pharmaceuticals, including insulin and antibiotics, equipment for the treatment of chronic diseases, as well as diagnostic devices (X-ray machines and laboratory tests), is permitted.

The supply of dual-use technologies, the sale of medical goods to Iranian state organizations, as well as the use of sanctioned Iranian banks for payments, are prohibited.

Licensing of UN and International Organization Employees

OFAC provides special general licenses for UN employees, the Red Cross, and other international humanitarian organizations working in Iran.

Funding for humanitarian projects, travel by employees of international organizations, and payment of local expenses (office rentals, transportation services, food) is permitted. Cooperation with any organizations associated with Iranian government or military structures remains prohibited.

Communication devices and General License E under ITSR

General License E under the Iranian Transactions and Sanctions Regulations allows the export of software, communication devices, and digital technologies to Iran.

The export of smartphones, laptops, and tablets, antivirus software and cybersecurity tools, as well as online communication platforms (messengers, video call applications), is allowed.

The supply of technologies related to Iranian state structures is prohibited. Transactions with sanctioned companies and banks remain banned. Any technologies that can be used for intelligence or military purposes are prohibited.

Inheritance within the framework of sanctions against Iran

Many citizens of the USA and other countries may find themselves in a situation where an inheritance from relatives in Iran requires transferring funds through international banks. For this, OFAC has provided a general license allowing legal transactions in such cases.

The inheritance transfer from relatives residing in Iran, related to property rights payments (for example, the sale of real estate), is allowed. The main requirement is to use foreign banks that are not under sanctions for this purpose. Inheritance cannot be transferred from individuals associated with Iranian government structures.

How to Obtain an OFAC License for Iran?

If the specifics of your activity fall under one of OFAC’s general licenses, you can operate within these exceptions without additional authorization. If your company or transaction is not covered by the general licenses, you will need to obtain a specific license.

Before submitting an application, ensure that your activity does not fall under the scope of a general license. Check the OFAC General Licenses published on the official website. Determine whether your transaction falls under humanitarian or exceptional categories.

When applying for a special license, it is required to provide detailed information about your activities:

  1. Detailed description of the transaction: main partners, transaction volumes, purposes of the deal;
  2. Financial information: transfer amount, source of funds, transaction cost calculation;
  3. Contracts and agreements related to the operation;
  4. Identification data of transaction participants (legal entities, banks, private individuals);
  5. Justification for why the deal should be allowed despite the sanctions;
  6. Legal opinions confirming the legality of the transaction.

To submit an application, it is necessary to complete form OFAC-1265. The application can be submitted online through the OFAC portal or sent via electronic or regular mail.

The review timelines can vary from 2 to 6 months, depending on the complexity of the case. In some instances, the wait may be prolonged if additional verification is required. If the application is denied, an appeal can be filed or an attempt can be made to revise the deal structure to meet OFAC requirements.

Our law firm provides expert services for obtaining OFAC licenses: analysis of your activities for compliance with general licenses, submission of an application for a specific OFAC license, preparation of documents and legal justifications, interaction with OFAC, and support at all stages of the application review process.

Charity Donations and Humanitarian Support

Yes, charitable organizations can donate funds for humanitarian aid to people or organizations in Iran, but only in strict compliance with OFAC sanctions and regulations.

The U.S. government allows humanitarian support in Iran, as it is aimed at helping the civilian population and should not fund prohibited entities. However, any donations and financial transactions must comply with the rules of OFAC general licenses, which regulate fund transfers, supply of goods, and provision of assistance under the sanctions regime.

Donations can be made by non-profit charitable organizations of the United States, foreign humanitarian funds, individuals, and international organizations (Red Cross, UN, and others) that have permits to operate in sanctioned jurisdictions.

Financial donations must not directly or indirectly finance prohibited entities (Iranian government, armed groups, organizations on the SDN sanctions list). Under general licenses, funds can only be transferred for strictly defined humanitarian needs, such as food supply, medical assistance, access to clean water and sanitation, or housing recovery after natural disasters. If the donation amount exceeds the limit or is directed toward a broad humanitarian project, a special OFAC license may be required.

Consequences for Donating to Charities Involved with Iran

If a donation is made through intermediaries connected with Iranian state structures or terrorist organizations, it may lead to severe sanctions from the United States. Many Iranian charitable foundations are under OFAC sanctions, even if they officially declare humanitarian purposes.

If a transaction falls under suspicion, the bank may freeze the funds until an investigation is conducted. In case of rule violations, the donor falls into a risk zone, and their assets may be frozen.

Organizations or individuals that violate OFAC rules may lose the ability to conduct international transfers. Being added to sanction lists makes any operations in dollars illegal.

general license

Before donating money, it is important to check whether the charitable fund or humanitarian organization has an OFAC license to operate in Iran. Reliable options include the UN, Red Cross, WHO, and international organizations operating under OFAC licenses.

It is important to keep all documents related to donations (payment orders, letters of intent, agreements with humanitarian organizations. This will help prove the legality of the transfer if questions arise from regulators. If the donation amount is significant or falls outside standard humanitarian categories, you can submit a request for an OFAC Specific License. This will allow the transaction to be carried out legally and protect against potential claims.

Schedule a Consultation with a Licensing Lawyer

Our legal team specializes in sanctions law and is ready to help correctly interpret OFAC general licenses to avoid fines and asset freezes. We conduct legal due diligence of your activities, assess potential sanctions risks, provide compliance consultations, and advise on international transactions.

We provide:

  1. Consultations on compliance with the sanctions regime – we help determine whether your activities fall under general licenses;
  2. Analysis of transactions and financial operations – eliminating the risk of sanctions violations and potential inclusion in OFAC lists;
  3. Assistance in structuring business processes – we develop legally substantiated solutions that allow operating legally within the framework of sanction legislation;
  4. Support for financial transactions – we help organize legal methods of transferring funds or delivering goods to Iran;
  5. Obtaining a special OFAC license – if your activity does not fall under the General License, we will prepare and submit an application for a special license.

Contact us right now – our lawyers will help you legally work with Iran, comply with OFAC requirements, and minimize sanction risks!

Dmytro Konovalenko
Senior Partner, Attorney-at-law, admitted to the Bar (Certificate to practice Law #001156)
Dmytro Konovalenko is a member of the International Association of Lawyers, specializing in Interpol-related cases. He has successfully contested Red Notices, fought extradition requests, and implemented preventive legal strategies for clients across Europe, Asia, and the Far East. Additionally, he has extensive expertise in matters concerning OFAC regulations and economic sanctions.

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