U.S. sanctions compliance guidance for the provision of humanitarian assistance to Palestinian people

How to provide humanitarian assistance while complying with OFAC sanctions

Provision of humanitarian assistance to Palestinian people

The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) today published sanctions compliance guidance for the provision of humanitarian assistance to the Palestinian people.

The OFAC compliance communique [PDF 185 KB] (November 14, 2023) clarifies that U.S. sanctions “do not stand in the way of legitimate humanitarian assistance to the Palestinian people” and answers the following questions:

  • For the purposes of the non-governmental organization (NGO) general licenses, what are the authorized categories of activity?
  • Can money be donated to NGOs in support of humanitarian efforts in Gaza or the West Bank?
  • Can U.S. companies provide goods and services to NGOs conducting humanitarian activities in Gaza or the West Bank?
  • Can NGOs import fuel or gas for use in Gaza or the West Bank for their organizations to use in support of authorized humanitarian projects?
  • Are NGOs authorized to transfer funds to a designated group or blocked person in connection with an activity authorized by the NGO general licenses?
  • If a governing official with a leadership role is blocked under the Global Terrorism Sanctions Regulations (GTSR) or the Foreign Terrorist Organizations Sanctions Regulations (FTOSR), is the governing institution they lead considered blocked as well?


For more information, contact a professional with KPMG’s Trade & Customs services:

Doug Zuvich
Partner and Global Practice Leader
E: dzuvich@kpmg.com

John L. McLoughlin
Principal and East Coast Leader
E: jlmcloughlin@kpmg.com

Andy Siciliano
Partner and National Practice Leader
E: asiciliano@kpmg.com

Steve Brotherton
Principal and Global Export and Sanctions Leader
E: sbrotherton@kpmg.com

Luis (Lou) Abad
Principal, Washington National Tax
E: labad@kpmg.com

Irina Vaysfeld
E: ivaysfeld@kpmg.com

Amie Ahanchian
E: aahanchian@kpmg.com

Christopher Young
E: christopheryoung@kpmg.com

Gisele Belotto
E: gbelotto@kpmg.com

George Zaharatos
E: gzaharatos@kpmg.com

Andy Doornaert
Managing Director
E: adoornaert@kpmg.com

Jessica Libby
E: jlibby@kpmg.com
John Anderson
Managing Director
E: johneanderson@kpmg.com
Jenna Leigh Glass
Managing Director
E: jennaleighglass@kpmg.com

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