Which commodities are allowed to be exported to sanctioned countries under the Office of Foreign Assets Control general license on humanitarian grounds?

The Office of Foreign Assets Control (OFAC) administers sanctions programs that often include exemptions or general licenses for humanitarian reasons. The Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA) established a general authorization for the export or reexport of agricultural commodities, medicine, and medical devices to Iran and Sudan, and this principle is broadly applied to other sanctions programs. These exceptions are designed to ensure that sanctions target regimes and illicit actors while mitigating unintended harm to civilian populations by allowing for the provision of basic human necessities. These items are explicitly defined and do not cover dual-use products.

A. Gold and other luxury items: These are explicitly non-humanitarian goods and are often the target of sanctions to pressure sanctioned elites, not items permitted under humanitarian exceptions.
B. Iron and steel: These are industrial materials, not humanitarian aid. They can have dual-use applications and are typically controlled under sanctions regimes, not authorized for export.
D. Crude oil and petroleum products: These are strategic commodities and a primary source of revenue for many sanctioned states. They are a principal target of sanctions, not an exception for humanitarian trade.

1. U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC). "Trade Sanctions Reform and Export Enhancement Act of 2000 (TSRA) Program." This official documentation outlines the specific provisions allowing for the export of agricultural commodities, medicine, and medical devices. It details the scope and limitations of the general licenses. Available at: https://ofac.treasury.gov/sanctions-programs-and-country-information/trade-sanctions-reform-and-export-enhancement-act-2000-tsra-program

2. U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC). "Guidance on the Sale of Food, Medicine, and Medical Devices by Non-U.S. Persons to Iran." This document explicitly clarifies the U.S. government's policy of allowing the sale of humanitarian goods, defining them as agricultural commodities, food, medicine, and medical devices. See Section I, "U.S. Sanctions and Humanitarian Trade."

3. Code of Federal Regulations. "31 C.F.R. § 560.530 - Commercial sales of agricultural commodities, medicine, and medical devices." This section of the Iranian Transactions and Sanctions Regulations provides the legal basis and definitions for authorized exports of humanitarian goods to Iran, which serves as a model for other programs.

4. Nephew, R. (2017). The Art of Sanctions: A View from the Field. Columbia University Press. Chapter 4, "The Challenge of Precision," discusses the importance of humanitarian exemptions for agricultural and medical goods to maintain the legitimacy and effectiveness of sanctions regimes. (DOI: https://doi.org/10.7312/neph18224)