US Treasury Implements Humanitarian Authorizations Across Sanctions Programs To Comply With UN Resolution

On December 20, 2022, the US Department of the Treasury's Office of Foreign Assets Control (OFAC) issued or amended general licenses (GLs) and FAQs to implement United Nations Security Council Resolution (UNSCR) 2664, which establishes humanitarian carveouts across UN sanctions regimes. The development of UNSCR 2664 was co-led by the United States and Ireland, and the Security Council adopted the Resolution on December 9, 2022. The amendments to OFAC's regulations are set forth in OFAC's Final Rule published in the Federal Register (see here and here).

Treasury had set a goal of calibrating sanctions to mitigate unintended humanitarian impacts in the Treasury 2021 Sanctions Review.¹ In this regard, during the pandemic, OFAC had issued policies on humanitarian exports and COVID-19 relief in countries and territories subject to comprehensive US sanctions (e.g., Covered Regions of Ukraine,² Cuba, Iran, North Korea, and Syria) and countries whose governments are subject