COVID-19: Impacts On US Sanctions Regulation And Policy

The COVID-19 pandemic has had profound economic and political effects over the past several months. Increasingly, those effects have led a number of US policymakers, US allies, and others to question certain US sanctions policies, and triggered debate over new sanctions with respect to the novel coronavirus and alleged coverups of information related to it. We urge companies to track these developments and consider how sanctions relief related to COVID-19—and potential new sanctions—might create new risks to, or even opportunities for, their business.

US Humanitarian-Related Sanctions Relief

On April 16, 2020, the US Department of the Treasury's Office of Foreign Assets Control (OFAC) issued Fact Sheet: Provision of Humanitarian Assistance and Trade to Combat COVID-19 (Factsheet), a comprehensive compilation of all regulatory guidance, exemptions, and exceptions that, to varying degrees, allow humanitarian-related trade with countries and territories subject to