On December 20, 2022, the United States Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced the amendment of multiple regulations to add or revise certain general licenses across OFAC sanctions programs to ease the delivery of humanitarian aid. This is a significant development for non-governmental organizations, including public charities and private foundations, that provide humanitarian aid in places where the need is greatest and these amendments will ease the compliance concerns associated with the provision of such aid. Although careful, individualized transaction review is still a must, most aid programs will qualify under the new general licenses.
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