On June 17, 2021, the US Department of Treasury’s Office of Foreign Assets Control (“OFAC“) issued General License N (“GL N“) authorizing certain COVID-19 related transactions and activities through June 16, 2022, involving Iran. The recent authorization from OFAC is an effort to “further aid the global fight against COVID-19” according to its press release. GL N is part of OFAC’s efforts under National Security Memorandum-1. This new authorization may provide much-needed support to Iran, which is greatly affected by the COVID-19 outbreak in conjunction with the broad restrictions imposed on trade with Iran due to U.S. sanctions.
GL N authorizes certain transactions and activites related to the diagnosis, treatement, or prevention of COVID-19. These transactions and activites range from the exportation of pandemic technology (e.g, surgical gloves, facial shields, respirators, etc.) to importation of non-functioning medical technology for the purposes of maintenance. The three major categories of activites that OFAC outlines in GLN is (1) exportation of goods or technology; (2) importation of, or dealings in, certain COVID-19 related goods and; (3) exportation or importation of COVID-19 related services. To ensure these transactions and activites can occur, OFAC is authorizing certain transactions to occur with the involvement of the Central Bank of Iran (“CBI”), as well as the National Iranian Oil Company (NIOC).
In addition to issuing GL N, OFAC issued six Frequently Asked Questions (“FAQs”), clarifying the scope and effect of GL N and other additional general licenses for similar purposes—FAQ 906, 907, 908, 909, 910, and 911. In particular, FAQ 910 explains OFAC’s expectations for US financial institutions when processing funds transfers (or trade finance transactions) when handling the abovementioned transactions. For example, a US financial institution can rely on the originator to ensure compliance with GL N so long as that financial institution does not definitely know the funds transferred are not in compliance with the GL N.
Additionally, according to FAQ 911, engaging in activites authorized by the GL N would not, generally, put a non-US person at risk of being designated as a Specially Designated National. However, understanding GLN and the potential risks that it carries can be complicated—even if the intent of the person using GL N is well intentioned. It is important to consult a U.S. sanctions attorney prior to engaging in any COVID-19 related trade with Iran.
In June 1990, the worst natural disaster in Iranian history devastated northern Iran when an earthquake hit the region and caused widespread damage. In response to this earthquake, infamously named the Manjil–Rudbar earthquake, the Iranian Diaspora came to the aid of their native country through donations and fundraisers. Notably, a group of these responders were Iranian-Americans in Los Angeles who originally founded the humanitarian organization Relief International to aid the cause. Today, Relief International is one of the largest international humanitarian aid organizations in the world and helps communities in over 15 nations across three continents.
Leading the organization since 2014 is Nancy Wilson. Ms. Wilson received her B.A. in Political Science and Economics from Stanford University and her M.B.A. from the Stanford Graduate School of Business. Following 16 years in development and the private sector in Africa, Nancy served as a leader at the Jonathan M. Tisch College of Civic Life at Tufts University. Today, in addition to serving as the CEO of Relief International, Ms. Wilson continues her humanitarian work as the Treasurer of InterAction, the largest network of international non-governmental organizations. At Relief International, Ms. Wilson champions its mission of striving to turn fragile communities into resilient ones. By specifically targeting healthcare, education, economic opportunities, and water and sanitation, Relief International works within communities to foster hope and self-sufficiency. While the organization’s work began in Iran and has grown its reach to the entire world, their programs in Iran have grown of late. From providing aid at times of environmental fragility to ensuring Afghan refugee children are ready to succeed in school, Relief International has been uniquely essential in providing humanitarian aid to Iran’s most vulnerable, particularly those in rural areas.
One of Relief International’s most prominent programs in Iran is its involvement with Iran’s Afghan refugee population. Ms. Wilson recognizes this program as an ongoing venture to work with local officials and the community. “We started off in a very small way, just helping some of them get access to winter blankets and shoes and things they needed to survive the very cold winters because they are, in many cases, very poor families living in very meager housing. And then over time, as we built our relationships with local government officials and with the Afghan community itself, we’ve had some amazing programs that have worked on access to education and access to healthcare.” By working with a refugee population, Ms. Wilson highlights the need to make the community feel cared for and valued. Wilson explains that “we’ve been able to work with Afghan [refugees] to get properly registered in Iran by enrolling their children in school, which has protected them from deportation and to ensure they get access to healthcare.”
While Relief International’s work with Iran’s Afghan refugee community is transformative, their work with this population does not stop there. Ms. Wilson has helped the organization lead one of her favorite initiatives: The School Readiness Program. The program includes an eight-week summer program for children who have had no exposure to formal education. Ms. Wilson recognizes this program as completely changing opportunities for Afghan refugee communities in Iran: “If you take a kid who has never been to school, has never had any homeschooling of any sort, and drop them in a first-grade class, they will not succeed. They don’t know how to sit down, how to hold a pencil, how to get along and play with their classmates, and so on. The program works by teaching the children everything from navigating a classroom to brushing their hair to dressing themselves for school – ultimately setting them up to become a successful student when they venture into a classroom in the fall. The impacts are life-changing.”
Ms. Wilson describes, “It’s been so heartwarming to see some of these kids suddenly able to go to school, have friends, and be learning. The parents are happier, the kids are happier, and it’s just delightful.” Ms. Wilson especially recognizes the importance of working with both Iranian locals and Afghan laborers to create outreach workers and bridge builders in the community. Ms. Wilson explains that the duality is important so that “when the kids come to the class there will be someone from the Afghan community and then also someone who is Iranian and knows what the classrooms are like and has been trained on how to do this kind of remedial and non-formal education to help prepare kids for formal education.”
What truly makes Relief International’s work unique, beyond helping to solve many of the world’s most dire dilemmas, is their commitment to building partnerships and alliances with local governments and communities. Ms. Wilson expands on this: “97% of our staff globally are local nationals. So we hire Iranians in Iran, we hire Turks in Turkey, we hire Jordanians in Jordan, and so on.” By working with and at the pleasure of nations and their citizens, Relief International has the unique ability to empower communities to uplift themselves.
However, Relief International faces unique hardships due to the inflation of Iran’s national currency. Inflation has led to sweeping worries across the country and has made life harder for many Iranians. Ms. Wilson explains that Relief International is not especially exempt from these problems. While her organization has not been importing humanitarian supplies until recently, it is still a troublesome bump in the road towards accessing basic human needs. Ms. Wilson explains, “If you’re helping to rebuild schools and you need cement and the cost of cement has gone up because of inflation and because of sanctions, then it’s just going to cost more to build that school and it’ll take a longer period of time.”
While Relief International is heavily involved in Iran, they hold an international presence as well. Darfur, Sudan is home to one of Ms. Wilson’s other favorite programs. Wilson explains that Relief International found that child malnutrition was a uniquely dire and grave problem facing the community, which led to its now elaborate initiative in Darfur. The Darfur program reflects what Relief International and Ms. Wilson have dubbed the RI Way: community involved, locally driven and planned, and built step-by-step. There is a push to build local capacities and help create self-sufficiency within communities based on their own needs, and through this, an entire program is customized from the ground up.
Relief International’s work is always changing to help meet the world’s demands. With the rapid rise of COVID-19 in Iran, Relief International has quickly responded by providing massive amounts of supplies to Iranian hospitals. It is sourcing locally and internationally to get essential masks, gowns, and test kits. RI is also spreading information about COVID-19 to Iran’s rural communities. Ultimately, Relief International’s pursuit to foster peace, quell conflicts and fragility, and enable access to basic human needs is essential in fostering a peaceful world. While there are a multitude of dilemmas, tragedies, and fragilities across the world, the work that Nancy Wilson leads at Relief International highlights the hope for a brighter future for all communities, from Iran to Darfur and everywhere in between.
If you are interested in learning more about Relief International or donating to the organization to further their work, visit their website at https://www.ri.org.
On April 18th, Iran, began to formally open up “low-risk economic activities,” including major shopping centers such as the Grand Bazaar. Despite concerns that this will increase infection rates in the country, the decision was made to stimulate the economy. Iran already suffered a 20 percent youth unemployment rate prior to the outbreak and a reported 50 percent of Iranians surveyed have lost their income due to the virus. Earlier this month, Iran refused medical aid from the U.S., a nation suffering most from the pandemic, and rather demanded the removal of sanctions. The decision to slowly open up the economy is likely made in an effort to prevent further harm to the economy as it endures pressure from both sanctions and the pandemic.
Likewise, the U.S., which has over 1,000,000 confirmed COVID-19 cases, has plans to slowly re-open the economy. This month, President Trump announced his three-phase guideline for “Opening up America Again.” The decision comes after concerns that the lockdown will take a toll on the public and the economy. However, the future appears to indicate some positive early signs as New York, one of the hardest-hit cities in the U.S., continues to witness a descent in the curve as the infection rate drops from 1.4 to 0.9.
As some countries look to open up their economies and slowly adjust to the new normal, the impact of the pandemic on global relations remains unclear. China continues to reject allegations that the virus originated in a Wuhan laboratory, was accidentally released, or that it knowingly failed to take adequate measures to protect the international community. However, Germany, the UK, France, and the U.S. are pressuring China to claim responsibility for the pandemic, with Germany issuing China for a £130 billion invoice for the damages incurred by the virus. Vera Jourova, Vice President of the European Commission, also criticized the European Union’s dependency on other countries, specifically China, for medical supplies and called for re-assessing the supply chain and attempting to increase production within Europe.
The COVID-19 outbreak has posed a challenge to countries as they struggle to contain the virus while also maintaining the economy. While global interconnectivity has its benefits, this pandemic has highlighted its dangers and the downsides of dependency on other nations.
This month, the Iranian-American Chamber of Commerce spoke with Shabnam Rezaei, co-founder of Big Bad Boo Studios, a children’s production company, and Oznoz, a subscription video on demand (SVOD) platform which features over 200 cartoon shows in 10 different languages, including many quality shows in Persian for Iranian-American families. Inspired by her Iranian heritage and in an effort to foster inclusivity, Ms. Rezaei has created groundbreaking changes in children’s entertainment.
Born in Iran, Ms. Rezaei moved to Austria at a young age, where she attended an international school. Exposed to multiple languages and cultures early on in her life, Ms. Rezaei stated that her experiences and diverse background are directly reflected in the shows that she creates and the business products that she produces.
Ms. Rezaei initially worked on Wall Street. Following September 11th, she created the online magazine PersianMirror, highlighting various aspects of Persian culture, in an effort to change the emerging negative narrative that Iranians were “lumped into.” Through PersianMirror, she was approached by Dustin Ellis, an aspiring writer and director who worked with her to create their first cartoon project, Babak and Friends: A First Norooz, an animated film about a young Iranian-American re-connecting with his Persian culture.
In her role at Big Bad Boo Studios, her work has included series such as The Bravest Knight, 1001 Nights, 16 Hudson, Mixed Nuts, and Lili & Lola. Lili & Lola is a preschool series about an Iranian-American family with lots of fun adventures and holiday episodes such as Yalda and Norooz. The cast of the show includes comedian Maz Jobrani, who plays the voice of the father. Lili & Lola can be found on Oznoz, Youtube and Amazon Prime Video. The show also has 6 Persian-learning games for free in the Apple App store, which teach the Persian Alphabet, Numbers, Shapes, Vocabulary and many other fun preschool topics. In addition, Big Bad Boo and Oznoz have Youtube channels with full episodes and Big Bad Boo’s content can also be found on Amazon Prime Video. All of the shows are available in Persian on Oznoz, for those families who are raising their children with Persian and want quality content to help with their children’s language learning abilities.
Although Ms. Rezaei originally began with the goal of representing Iranian culture, her mission has “now expanded to representing every single person whose voice may not be heard.” Her productions are multicultural as they feature a diverse group of characters in storylines that children and families from underrepresented groups can relate. This is an integral part of Ms. Rezaei’s work as she believes that “there is nothing more important than a person feeling like they matter, seeing themselves in the media.”
Big Bad Boo Studios and Oznoz have gained the respect of everyday families who appreciate the validity and pride provided to their children through Ms. Rezaei’s work. Doing so, however, has by no means been easy. The challenge fuels Ms. Rezaei to continue to “innovate with difficult topics and push with telling stories that no one else wants to tell,” in an effort to show the common humanity we share with different cultures and families, while fostering inclusivity in children’s entertainment.
Iranian-American organizations at universities across the country flourish because of the young generation’s commitment and dedication to their heritage and communities. These communities are often started from the ground-up and require hard work and a strong love for Iranian culture. This can be seen no better than at Emory University in Atlanta, Georgia through their Persian Cultural Association – the PCA. The PCA was inactive for several years before being re-chartered by students Anisa Hofert and Sana Matloub in late 2018. Sana, co-President of the PCA, is a senior majoring in Human Health and minoring in Persian Language and Literature.
As a member of the Iranian-American community, Sana felt it was necessary to have a cultural hub at her university. In the process of re-chartering the student organization, she spoke to Emory University’s student college council about the need for the cultural space. “Persians have a deep connection to their roots and when they are away from family it makes it hard to celebrate cultural events such as Nowruz. Persians just enjoy being around others and spreading [their] beautiful culture.” With tireless work from both Sana and Anisa to create the club, PCA was re-born. As the club is more involved and active than ever, the PCA holds monthly meetings where students meet and spend time together. Sana explains that members “watch Persian films, have chai, do homework, hold general body meetings, or [host] lectures (e.g. the Persian professor at Emory was willing to come in and lecture on calligraphy).” On a larger scale, the student group holds events to commemorate holidays like Nowruz. As the group has grown substantially over the past few years, their first Nowruz party was supposed to happen this Spring but was canceled due to pandemic.
Starting from scratch, the PCA highlights the Iranian-American community’s will and devotion to creating spaces for gatherings. While there are structural barriers, especially in smaller universities and smaller towns, this commitment to Persian culture is forever present. As Sana and Anisa highlighted, their university experience would not be the same without a Persian community. Though Sana is graduating in May, she feels hopeful about the PCA’s growth. Especially with the heartbreaking end that the pandemic has brought to many students’ spring semester, Sana still has hope for the group’s future. “I’m hopeful that PCA will grow next year and the years to come since we have raised so much money for large events [that should]attract more members to create a larger Persian community.” As evinced by the dedicated work of Iranian-American students at Emory University, this is only the start for PCA.
On April 16, 2020, the Office of Foreign Assets Control (OFAC) issued a Fact Sheet highlighting the most relevant exemptions, exceptions, and authorizations for humanitarian assistance and trade under the Iran, Venezuela, North Korea, Syria, Cuba, and Ukraine/Russia-related sanctions programs. The Fact Sheet outlines specific guidance for OFAC-administered sanctions programs related to personal protective equipment (PPE) and other Coronavirus Disease 2019 (COVID-19)-related humanitarian assistance and trade.
In its Iran-specific section of the Fact Sheet, OFAC states:
“For COVID-19 related support, Treasury continues to stress that U.S. and non-U.S. persons may provide such humanitarian goods — including medicine and medical devices — to Iran under existing exemptions, exceptions, and authorizations in U.S. sanctions laws and regulations. For example, most medicine and medical devices, including certain personal protective equipment and other items used for COVID-19-related treatment such as medical gowns, medical eyeshields and goggles, surgical gloves, face shields, certain respirators and masks such as N95, N99, and N100 masks, and certain ventilators, already qualify for export and reexport to Iran under general licenses, without the need for further authorization from OFAC. There are certain limited categories of items that may also be helpful for COVID-19-related assistance (e.g., oxygen generators, full face mask respirators including Powered Air Purifying Respirators, certain diagnostic medical imaging equipment, and certain decontamination equipment), for which OFAC’s regulations set forth a specific licensing policy for review of license applications on a case-by-case basis due to concerns about potential end use of these specific items. OFAC is prioritizing and expediting review of these license requests.”
In a joint statement at the end of January 2019, the foreign ministers of France, Germany and the United Kingdom (known as the “E3”) announced the creation of the Instrument in Support of Trade Exchanges (INSTEX), in an effort to preserve the JCPOA. INSTEX is a special purpose vehicle aimed at facilitating non-dollar trade between European companies and Iran. Five other countries, Belgium, Denmark, Finland, Netherlands, and Sweden, later joined the mechanism in November 2019.
The creation of INSTEX was essential for trade to remain possible between EU and Iran, particularly because SWIFT, the main international payment system, suspended access for Iranian banks at the end of October 2018 in response to U.S. pressure.
INSTEX is somewhat of a barter system that allows companies in the EU to avoid the U.S. financial system altogether in their business with Iran by eliminating payments through third parties. In this system, a European company buying from an Iranian company will be matched with another European company selling to an Iranian company. The European buyer will pay the European seller, thereby completely avoiding any cross-border payments. Of course, this is only possible if the Iranian seller on the other side of the first transaction can also be paid by the Iranian buyer on the other side of the second transaction. That is why Iran had to establish a domestic special purpose vehicle counterpart to INSTEX called the Special Trade and Finance Institute (STFI). The STFI mechanism was developed after technical and expert negotiations between representatives of Iran and the E3.
After months of preparation and negotiation, the E3 announced that the first INSTEX transaction was concluded on March 31, 2020 and that these goods are now in Iran. The statement did not exactly describe the goods or the parties involved in the transaction. However, the statement did announce that this first transaction covered medical equipment used to combat the COVID-19 outbreak in Iran.
Originally, INSTEX was conceived as a way to help match Iranian oil and gas exports, vital to the Iranian economy, against purchases of EU goods. However, those ambitions were toned down presumably as a result of strong pressure from Washington. It appears that for now, in the few participating European countries, INSTEX will work with smaller companies that are not engaged in business with the U.S. Even then, its operation initially is limited to exports of food and medicine, which are excluded from U.S. sanctions. Nevertheless, theoretically, it could grow to bring in other countries and its operation could be extended to trade in goods other than food and medicine.
Iranian-American groups emerge in every crevice of the country, from coast to coast. This can be seen in Minneapolis at the University of Minnesota, Twin Cities and their Persian Student Organization of Minnesota – known as PSOM. Leading the organization as co-president is Leyla Taghizadeh, a sophomore majoring in Neuroscience and minoring in Spanish. PSOM was founded in 2012 and has blossomed into a group that brings the university and the town’s Iranian-American community together. The central love for Iranian culture is evident, with the club often hosting group events to view Iranian films, learn how to cook Iranian food, and other activities to showcase Iranian culture and history.
PSOM celebrates large scale events as well as holding fundraisers and regular meetings for their members. Their largest event of the year is their Nowruz party: “Every year for the Persian new year, we throw a party gathering Persians across Minnesota, giving them a space to rejoice and celebrate the coming of the new year. The evening is full of good food, company, and dancing all highlighting Persian culture. It is also a space that we invite other cultures to join and learn about the Iranian community and how we celebrate the coming of a new year. ”
However, their large events don’t stop there. Every fall, PSOM hosts a large picnic fundraiser to raise money for the organization and their events for the year. This fundraiser is more than just a picnic; it represents a celebration of the Iranian-American community at the University of Minnesota: “Traditional Iranian soup (Ash-e Reshteh) and tea (chai) are provided and there are games (soccer, frisbee, and football) that people can play. Iranian music is on full blast while people can dance, socialize and enjoy an environment full of Iranian culture.” The fall picnic fundraiser has grown to become a celebration of Persian culture to ring in the new academic year of PSOM.
The beauty of organizations like PSOM is that their presence is felt beyond just the Iranian-American community. Leyla herself has seen the organization’s involvement with their town: “I have grown up in Minneapolis and have attended PSOM events my whole life.” She also recognizes that the organization blossoms by creating an inclusive environment to help educate all students on Iranian culture, “While we provide a space for Iranians to come together, we also try to share our culture with others by inviting people of other heritages to our events. We are attempting to teach anyone who is willing to listen about the joys of being an Iranian American.” PSOM represents the intersection of creating a space for students to embrace their culture as well as create a more closely-knit community, while simultaneously opening up the beauties of Iranian-American culture to the entire university.
The Iranian American Bar Association (IABA) was founded in D.C. in 2000 to educate the Iranian-American community on legal issues and ensure Iranian-American representation in the broader community. The IABA has since grown to become a nationwide organization. This month, the Iranian-American Chamber of Commerce spoke with Dr. Golnoosh Hakimdavar, President of the IABA D.C. Chapter, about how the organization is responding to the needs of the Iranian-American community across the nation, as well as the chapter’s targeted focus on D.C., Maryland, and Virginia.
The D.C. chapter achieves its mission through legal accessibility and events that it hosts throughout the year, including networking events. In the chapter’s most recent event, a legal clinic co-sponsored by the Iranian-American Community Center, attendees consulted with volunteer attorneys free of charge. The chapter coordinates with the IABA National Board to provide informational material for the community. In light of the coronavirus outbreak, the IABA released a ‘Know Your Rights’ document to help guide those traveling from countries with COVID-19 level 3 travel warnings, which includes Iran. Following the travel ban, the IABA set up a team at the airport to help those affected by the ban and filed an amicus brief with the U.S. Supreme Court in support of Hawaii’s challenge to the travel ban.
According to Dr. Hakimdavar, the lawyers and members at the center of the organization are “driven by the service-oriented and volunteer nature” of the work. She emphasizes the importance of Iranian-American activism in the legal community. “As a community we have been at the center of many discussions whether they be political, societal…they are also legal and we as an informed group have the responsibility to continue passing on information to our community so they are acting and reacting to situations based on full information,” Dr. Hakimdavar says. By making legal information more accessible to the Iranian-American community in the DMV region, the IABA D.C. chapter hopes that individuals will become more aware of their rights, and how changes in the law impact them.
Community outreach is at the center of the IABA D.C. chapter, and Dr. Hakimdavar encourages individuals to email the IABA D.C. chapter at email@example.com with any questions or if they feel that there is a matter that needs to be looked into. You can also support the IABA by becoming a member. Please note that you do not need to be a lawyer to do so.
The May 8, 2018 decision by the Trump Administration to withdraw from the Joint Comprehensive Plan of Action did not terminate existing sanctions exceptions and authorizations for humanitarian trade with Iran. However, the decision, along with further sanctions and uncertainty, had a chilling effect on the willingness of international banks to facilitate these otherwise legitimate humanitarian transactions. Prompted by these changes, politically neutral Switzerland began working in 2018 with U.S. and Iranian authorities, as well as certain Swiss banks and Swiss companies, on a plan to implement a humanitarian payment mechanism for Iran.
As a result of these efforts, the Swiss Humanitarian Trade Arrangement (SHTA) officially launched and became fully operational on February 27, 2020, after an initial pilot period in late January, which involved Geneva-based bank BCP and a shipment of Novartis cancer and organ transplant drugs worth approximately $2.55 million. It establishes a payment channel with a Swiss bank, through which payments for exports to Iran by Swiss-domiciled companies are guaranteed. The arrangement is open to companies domiciled in Switzerland, including those owned or controlled by U.S. or third-party persons.
Under the rules of this new arrangement, the U.S. provides assurances that the proposed transactions do not violate U.S. sanctions. In exchange, the system is subject to strict due diligence measures. Participating financial institutions commit to conducting enhanced due diligence to ensure that humanitarian goods reach the Iranian people. For example, both exporters and participating banks have to provide information on their business activities and partners in Iran. The mechanism is designed to ensure that no revenue or payment is transferred to the Iranian Government, by restricting the Central Bank of Iran’s role in facilitating the transactions.
In humanitarian terms, the SHTA comes at a much-needed time. Certain large Swiss companies like Nestle and drugmakers Roche and Novartis already produce in Iran, and could expand their production. The SHTA also could encourage smaller Swiss companies to export food and medicine to Iran. This, in turn, would improve the flow of humanitarian goods to the Iranian people. Even before the global coronavirus epidemic, many foreign banks had categorically refused to engage in Iran-related transactions, even for sanctions-exempt humanitarian trade. This reluctance contributed to soaring medicine prices in Iran and severe consequences, especially for people suffering from illnesses that require imported medication. The COVID-19 crisis has given rise to even greater concerns over Iran’s access to humanitarian trade in food, medicine, and medical supplies. The SHTA may prove to be a significant player in the international network seeking to preserve humanitarian trade with Iran and avert humanitarian disaster.