On September 18, 2023, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) established a new humanitarian channel (“HC”) in Qatar to facilitate the provision of humanitarian assistance to the Iranian people. The HC is similar to humanitarian channels established under previous administrations and is designed to help the Iranian people gain access to food, agricultural goods, medicine, and medical devices, while ensuring that funds are not misused and is intended to supplement banking channels that may already be used for humanitarian trade pursuant to existing exemptions and OFAC authorizations.
OFAC issued two new Frequently Asked Questions (“FAQs”) relating to the HC.
- FAQ 1,134 clarifies that the HC does not allow funds to be released to the Government of Iran or payments to Iranian companies. The US will partner with the Government of Qatar and financial institutions operating the HC to monitor the HC for attempts by Iran to use the funds for purposes other than permitted humanitarian purchases.
- FAQ 1,135 states that parties interested in participating in transactions pursuant to existing exceptions and authorizations for the conduct of humanitarian trade with Iran may continue to do so outside of the HC.
Parties interested in participating in transactions under the HC should coordinate directly with the Qatari International Media Office at info@imo.gov.qa and may also contact the OFAC Compliance Hotline with specific questions.
The authors acknowledge the assistance of Vanessa Keverenge and Ryan Orange for the preparation of this blog post.
