Export Mechanism for Humanitarian Goods to Iran 'Fully Operational,' Treasury Says
The U.S.-Swiss joint mechanism used to export humanitarian goods to Iran is now “fully operational,” the Treasury Department said Feb. 27. Treasury also issued a general license and a series of frequently asked questions to clarify how the mechanism can be used.
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The mechanism, the Swiss Humanitarian Trade Arrangement (SHTA), was originally announced in October and set a high bar for compliance and due diligence in order for companies to export goods to Iran (see 1910250057). U.S. lawmakers have criticized U.S. sanctions for inadvertently blocking humanitarian exports to Iran (see 1912120027), but the State Department said the mechanism successfully completed its first set of exports in January and that it expects more companies to use it. That January transaction was aimed at demonstrating the “viability and effectiveness” of the SHTA, Treasury said, adding that the mechanism is now available for use by anyone who meets the due diligence standards.
General License No. 8, also issued Feb. 27, authorizes certain transactions with the Central Bank of Iran to allow companies to trade through the SHTA. The license blocks certain transactions, including with people and entities sanctioned under the Global Terrorism Sanctions regulations and the Iranian Transactions and Sanctions Regulations. Treasury further clarified the license in FAQs 821 and 822.
In FAQ 823, Treasury said non-U.S. persons “generally do not risk exposure” to U.S. secondary sanctions against Iran involving exports of agricultural goods, food, medicine or medical devices because those goods are “generally subject to exceptions” if they do not involve people or entities sanctioned for weapons proliferation. FAQs 824 and 825 provide an overview of the SHTA and how parties can participate.
In FAQ 826, OFAC said foreign governments or banks interested in creating a mechanism similar to the SHTA should reach out to the Office of Foreign Assets Control “to provide a proposed framework for evaluation.” Treasury said those proposals should “demonstrate careful consideration of the illustrative list of enhanced due diligence and reporting expectations” listed in the SHTA. Companies with Swiss jurisdiction may reach out to Switzerland’s State Secretariat for Economic Affairs SHTA@seco.admin.ch for more information on requirements for participating in the SHTA.