COMPLIANCE humanitarian aid and ensure a baseline of authorizations for the provision of humanitarian support across many sanctions programs .” 16 Going forward , these carve-outs will apply to all new sanctions regimes .
What is authorized ?
These new general licenses are a huge step forward in solving a complex problem that will require a multifaceted solution . They provide authorizations in four categories :
• The official business of the U . S . government
• The official business of certain international organizations and entities , such as the U . N . or the International Red Cross
• Certain humanitarian transactions in support of NGOs ’ activities , such as disaster relief , health services and activities to support democracy , education , environmental protection and peacebuilding
• The provision of agricultural commodities , medicine and medical devices , as well as replacement parts and components and software updates for medical devices for personal and noncommercial use
The authorizations include noncommercial activities designed to directly benefit the civilian population that fall into one of the following categories :
• Humanitarian projects to meet basic needs , including disaster , drought and flood relief ; food , nutrition and medicine ; health services ; and services for vulnerable or displaced populations
• Democracy building , including the rule of law , citizen participation , government accountability and transparency , human rights , access to information and civil society development projects
• Education , including combating illiteracy
• Noncommercial development projects
• Environmental and natural resource protection
• Peacebuilding , conflict prevention , conflict resolution , and disarmament , demobilization and reintegration programs
The general licenses for NGOs also permit fund transfers to sanctioned or designated entities for the payment of taxes , fees , import duties or the purchase or receipt of permits , licenses or public utility services . These include authorizations for both the Global Terrorism Sanctions and the Foreign Terrorist Organization Sanctions Regulations . General licenses for the official business of the U . S . government authorize all transactions .
Due diligence and risk mitigation are here to stay
Both the U . S . government and NGOs have made it clear that these new licenses are not a blank check , and they will not change the way NGOs do their part to prevent sanctions violations and terrorist financing . As one U . S . government official stated off the record , “ Risk mitigation is here to stay .” NGOs resoundingly agree .
Humanitarian aid , development and peacebuilding communities have a vested interest in protecting their donors , partners and the populations they serve , as well as their own
74 acamstoday . org