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February 25, 2020

NIAC Sends Letter to Treasury Encouraging Steps to Ensure U.S. Sanctions Do Not Hinder Iran’s Ability to Address Coronavirus

Today, the National Iranian American Council (NIAC) wrote Treasury Secretary Stephen Mnuchin to encourage immediate steps to ensure that U.S. sanctions do not inhibit humanitarian relief to respond to the outbreak of Coronavirus, or COVID-19. As the letter notes, Iran is in a poor position to handle the outbreak of a highly communicable virus like COVID-19. Sanctions have greatly harmed the healthcare industry in Iran, limiting imports of key medical devices and Western pharmaceuticals. Given widespread concerns regarding the humanitarian impact of sanctions, which have been exacerbated by recent decisions to tighten sanctions on Iran, it is vital for the U.S. to take immediate steps to ensure relief can be delivered.

NIAC President Jamal Abdi released the following statement accompanying the release of the letter:

“The Coronavirus does not respect national boundaries and represents a shared threat to global health and the international economy. Unfortunately, Iran is likely to fight the spread of this virus with both hands tied behind its back thanks to the Iranian government’s own ineptitude and crushing international sanctions. The Trump administration should stand with the Iranian people, ease humanitarian sanctions and consider the provision of direct aid to Iran through a third-party country.”

You can see the text of the letter below:

February 25, 2020

Treasury Secretary Stephen Mnuchin
U.S. Department of the Treasury
1500 Pennsylvania Ave NW
Washington, DC 20220

Dear Secretary Mnuchin,

We write to encourage the Treasury Department to take immediate action to ensure that sanctions on Iran do not inhibit the provision of humanitarian assistance aimed at treating and halting the spread of COVID-19, also known as the Coronavirus. Given the major global health and economic ramifications that are at stake, it is vital to ensure that the international community has all the resources it needs to control the outbreak, treat the victims and halt its spread.

While it is difficult to ascertain the full scope of the outbreak, COVID-19 has spread to at least 100 individuals and killed 16 in Iran. Many believe the outbreak to be far more widespread, given the lack of testing kits and the Iranian government’s lack of transparency.

Unfortunately, Iran is in a poor position to handle the outbreak of a highly communicable virus like COVID-19. While Iran is capable of producing some of its own medicine and supplies, including hygienic masks, Iran’s ability to import needed medicine and supplies in spite of broad-based sanctions is likely to be quickly put to the test. While many forms of humanitarian trade with Iran has long been generally licensed, numerous outlets have outlined how sanctions have limited Iran’s ability to import medical supplies and specialized pharmaceuticals manufactured in the West. 

Recent policies enacted by the U.S. risk further undermining humanitarian trade, including urgent relief efforts. In particular, the September designation of the Central Bank of Iran (CBI) under terrorism authorities and the October designation of Iran as a jurisdiction of primary money laundering, respectively, upended existing humanitarian exceptions and created new risk for even legitimate transactions with Iran, threatening remaining humanitarian trade. Moreover, the announcement of a new humanitarian mechanism to facilitate humanitarian trade with Iran has had the unintended effect of complicating legal pathways to effectuate such trade. While there has been a channel set up through the Swiss government, that channel is limited to Swiss companies and is thus likely too narrow in scope to facilitate relief on the scale that may be needed. 

We encourage the Treasury Department to take immediate steps to ensure that sanctions do not inhibit relief, including by issuing a general license for humanitarian relief to respond to the COVID-19 outbreak, providing renewed guidance on how parties can lawfully conduct humanitarian trade with Iran, and restoring humanitarian exceptions permitting the involvement of the CBI and other sanctioned financial institutions. Additionally, the Treasury Department should provide updated guidance to interested parties noting that the donation of medical devices to Iran, including medical masks, to relieve the suffering of the Iranian people is exempt from regulation under the Iranian Transactions and Sanctions Regulations, 31 C.F.R. Part 560, and any other applicable U.S. sanctions regulations, including the Trade Sanctions Reform and Export Enhancement Act (TSRA). Finally, the Administration may wish to explore the provision of direct relief, potentially by partnering with third party countries, in order to show good will in responding to the shared threat of COVID-19.

We stand ready to assist and provide any insight we can regarding humanitarian complications caused by U.S. sanctions, the scope of the outbreak in Iran and any other related issues.


Jamal Abdi
President, National Iranian American Council (NIAC)

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