Letter of response to the US Treasury Department's Guidance on Humanitarian Relief to Iran

Following the two earthquakes in Iran’s north-western Azarbayjan Province and the pressure of humanitarian agencies and individuals on the White House to facilitate  the deliverance of humanitarian relief to the victims, the US Treasury Department announced its updated Guidance for Humanitarian Assistance to Iran.  We publish the response from  Dr David Laylin, the Senior Advisor at the Centre for the Study of Islam and the Middle East (CSIME) to Paul Monteiro, Associate Director, White House Office of Public Engagement. 

Dear Mr. Monteiro,

Your memo purports to show that the US Government wishes to facilitate humanitarian help for the people of Iran - in general and specifically for victims of the recent earthquakes.

Unfortunately, the message consists of "empty words." Note that:

1) The biggest problem is that Western, Iranian and other Middle Eastern
   banks are afraid to handle financial transfers, even if the
   originator has an OFAC license! In addition, OFAC personnel are
   prohibited from identifying banking channels for sending money to
   Iran. I know this from personal experience.

2) As so often happens with US Government dealings with Iran, the laws
   and regulations do not take into account realities in Iran. For
   example, Iranian charities must pay high importation duties, unless
   humanitarian goods come in through the Ministry of Health. However,
   OFAC does not allow that. In addition, it is difficult to get
   emergency help to the needy, without involving Government organs.
   Again, OFAC prohibits any involvement by agencies of the Iranian
   government.

If the Administration really wanted to help, it would "fast track" a general OFAC license for humanitarian help by NGOs and individuals, identify approved banking channels, and allow participation of pertinent Iranian agencies like the Red Lion and Sun.

As it is, your memo may serve some political purpose, but has no real value for those suffering in Iran and not able to wait two months for approval of an OFAC license.

Sincerely,

David Laylin
Senior Advisor
Center for Studies of Islam and the Middle East (CSIME)