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Law360 (June 18, 2021, 9:02 PM EDT) -- The Biden administration temporarily lifted sanctions on Iran, Venezuela and Syria to allow for the shipment of COVID-19 medical equipment, including vaccines, tests and face masks.
The yearlong general licenses that the U.S. Department of the Treasury issued Thursday broaden already existing humanitarian exemptions to the Iranian, Venezuelan and Syrian sanctions programs to cover additional COVID-19-related activities.
The Treasury Department explained it was easing the sanctions programs under President Joe Biden's national security memorandum directing federal agencies to assess whether U.S. sanctions were hindering the global COVID-19 response.
"These new authorizations will further support the critical work of governments, international organizations, non-governmental organizations, and private sector actors in providing COVID-19-related assistance to the people in certain sanctioned jurisdictions," the Treasury Department said.
The general licenses will expire on June 17, 2022.
Weeks after the World Health Organization declared COVID-19 a pandemic, the Trump administration announced it would expedite and prioritize the export of medical and safety equipment to Iran. The decision came shortly after Republican and Democratic national security leaders called on the White House to ensure that sanctions didn't interfere with COVID-19 relief.
But promises to quickly process Iranian COVID-19 export requests didn't eliminate the need for businesses to apply for the license, according to trade attorney Doug Jacobson of Jacobson Burton Kelley PLLC.
The new licenses provide a general authority for certain exports to Iran, Venezuela and Syria. However, Jacobson called the general licenses "very narrow" on a Friday call.
"It's only dealing with COVID-19 prevention, diagnosis and treatment," Jacobson said. He also pointed out that exports are a "two-way street" — though the U.S. could authorize more shipments, the other governments would have to allow it.
"It's a nice gesture, but how practical these will be remains to be seen," he said.
On March 26, dozens of humanitarian, human rights and other civil society groups called on the Biden White House to provide immediate sanctions relief for countries subject to a strict sanctions regime, including Iran. The sanctions programs have already led to medical supply shortages, and allowing them to continue risks turning sanctioned locations into virus hotbeds, they said.
They recommended that Washington, D.C., issue a temporary general license that exempts "at minimum" COVID-19-related medical equipment and goods that can address food security and water supply issues.
--Editing by Daniel King.
Correction: A previous version of this story incorrectly described the Treasury Department's April 2020 COVID-19 action. The error has been corrected.
For a reprint of this article, please contact reprints@law360.com.
