OFAC LICENSE UPDATE

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Important OFAC Update           Farsi Translation


We have important news which impacts our sponsored Iranian children. 

You have followed us through the frustrating and unprecedented delay of our OFAC license renewal for several months now. We finally have a response from OFAC and our renewal application to send stipends to Iranian children was not approved. 

While the news is disappointing for all of us,  we are optimistically coordinating sponsorship funds to send food packages. Food aid to Iran is not sanctioned but it is difficult.  We need a food distribution system because until it is established, our 6,000 Iranian children cannot receive anything more from Child Foundation sponsors and donors. We hope to report soon that each  sponsorship payment going forward will provide food packages for your child as was our program model in the past.Please know, food packages would be a short-term solution.

While we work for a more favorable decision on a new OFAC license application, this may be the best support we can provide.  Food packages are useful to vulnerable families facing food shortages and a roughly 50% increase in prices since last year. Many of you may remember that food packages are what Child Foundation provided children prior to our first OFAC license for cash transfer of stipends in 2014. 

OFAC’s decision is a setback . Together, we will  reestablish the former stipend system soon. The decision’s rationale is not yet clear as there is no reason to believe our programming or finances are at fault. However,  understanding the decision to soon secure a different outcome is Child Foundation’s top priority. Child Foundation is determined to restore the program to its previous state as soon as possible. Our legal team, board of directors, and staff are working hard.  Please donate to our general fund to assist our resource-intensive efforts

We need you. Your sponsored children need you. 

We are committed to the children of Iran just as we are to the children of Afghanistan, Indonesia,  Cambodia, Nepal, and others in need. We are committed to transparency. Keep an eye out for future updates.

If you have any questions or concerns or would like to make a significant donation, please contact our office by email at  [email protected]  or by phone at (503) 224-0409.

OFAC is the Office of Foreign Asset Control, as part of the U.S. Department of the Treasury that controls the financial transactions related to foreign sanctions, including all financial transactions with Iran. To bypass sanctions, we need permission. For more than a year, we were working on renewing our previously awarded OFAC license.

There are many types of licenses OFAC grants. We have a separate license from OFAC, a General License E, which allows us to send money to Iran for humanitarian aid. However, this same license does not support recurrent sponsorship dollars to support child education. 

For several months, our sponsored children received a smaller portion of their monthly stipend from our partner in Iran because we were unable to send your funds. Now that we have a decision from OFAC about sending money, we are taking steps to address it.  We are urgently working on preparing a food package distribution system because until it is established, our 6,000 Iranian children will not receive anything more from Child Foundation sponsors and donors.  Food is not subject to sanctions. Given the steep increase of food prices in Iran, such packages will relieve some of the burden felt by vulnerable families and help children focus on their education. Additionally, Child Foundation has provided food packages in the past. We know they are useful to Iranian families.

Great question! Our entire team cares deeply about these children and is working hard to address this issue and restore the fund transfer through available legal means. We are addressing the renewal denial on many levels. We hired a new legal team because we believe we need new insights and this team is investigating OFAC’s decision making process and may file a new application depending on what is discovered. Filing a Freedom of Information Act (FOIA) application may help us learn more though it is very time consuming. Our staff is researching partnerships, strategies for a stronger application, and expansion of our programs to better support communities  as a whole  rather than primarily individual children. These are resource-intensive efforts.

We will use your sponsorship to purchase basic foodstuffs like rice, beans, lentils, and oil which are both commonly used and nonperishable. Our sponsored children are at risk of leaving school even though they show a great interest in learning. Food insecurity is a huge barrier that vulnerable families’ wrestle with in many parts of the world, including Iran.

We are not completely sure at this time but are committed to transparency with our community of supporters.  This is the worst climate for humanitarian aid to Iran we have ever seen but our legal team is optimistic.

Child Foundation first applied and was awarded permission in 2014. Each renewal application afterwards was renewed with no delays or problems. There have been no significant changes to Child Foundation’s operations or delivery, nor are we aware of any changes in the requirements for issuing or renewing such a license, or any other administrative grounds for license delay or refusal. All documentation was submitted on time, well in advance of the former license’s expiration. We requested guidance from OFAC during the delay and received no helpful information or elements we could clarify.

No.  This is the worst climate for humanitarian aid to Iran we have ever seen and it is the first time this application has been significantly delayed or denied. Child Foundation has received timely OFAC licensure since first applying in 2014. The process in 2019 stretched an unprecedented number of months and OFAC did not provide an explanation, a workable timeframe, or guidance even after we submitted formal requests.

Yes. The outcome is not what we were expecting nor is it best for the children we support. However, a rejection of the renewal application means we are no longer waiting. We can act. Further, OFAC is sure to communicate with us more. During the delay, there was little we could do as it is difficult to answer unasked questions. There are options now and we are optimistic that better communication will beget increased OFAC transparency about their decision making process.

Also, given our experience, we are in an excellent position to champion more navigable and reasonable policies and procedures for sanction exemptions in the future. We hope many organizations doing excellent work may benefit from our insights, support, and advocacy for children living in sanctioned countries.

We are confident that, given enough time and resources, we can clarify the importance of our mission and legally-sound nature of our programs. We are committed to sharing updates with our sponsors often.

It is important to remember OFAC guidance states that “OFAC also administers a favorable licensing policy for projects and activities in or related to Iran that are designed to directly benefit the Iranian people in the areas of democracy and human rights and academic and cultural exchange programs. This means that OFAC will interpret its regulations to allow such projects and activities to the greatest extent permitted by U.S. law.” We are confident that our child education program in Iran fits well within OFAC’s licensing policy.

Our legal team has advised Child Foundation to hold donations to sponsored children during that time until we have clear guidance from OFAC. Once we have clearance, we will do everything we can to use these funds for your sponsored children in whatever way possible. Please be patient during this time. We will notify the community once we have more information. 

Child Foundation believed that OFAC’s decision meant we were unable to send any kind of support until the decision was reversed or a new application was approved. However, we discovered important information since. And we are happy to report that you can still sponsor your child through food packages as food is not sanctioned and sending this support does not endanger a future OFAC application. If you have any questions about the conversation you had with Child Foundation staff, please contact our office by email at [email protected]  or by phone at (503) 224-0409.

While a full stipend is preferable, food packages are still beneficial to children trying to learn. Keep in mind that the conditions in Iran have not improved. Food prices have risen alarmingly in the last year and the problematic economy has also resulted in some food shortages. Further, hungry children struggle to focus in school. If you cancel your sponsorship, we will need to find a new sponsor to fund your child’s food packages.

No, the other countries we work in are not sanctioned like Iran is. Your sponsorship dollars for children in Afghanistan, Indonesia, Nepal, and Cambodia will be delivered as they were before.

You are welcome to contact our office by email at [email protected] and by phone at (503) 224-0409. We would appreciate a personal conversation with you about these details though we, ourselves, are still waiting on answers from our legal team and the OFAC office.

Communicate with your sponsored child : What a source of encouragement you can be to a student worrying about their future and struggling to remain motivated in school. Please send messages to us for them. You can express your faithful support and pledge to keep working on their behalf. 

Support Child Foundation’s efforts : A generous gift above and beyond your regular sponsorship would also go a long way in supporting the children we all care for. The resources we need to secure, once again, permissions from OFAC will come from our General Fund. It is a resource-intensive process. 

Volunteer : We need volunteers to step up during this complicated time: Translation, data management, graphics design, videography, communications, outreach, and event planning for awareness and fundraising.

Share ideas and insights: We are eager to partner with communities and individuals that share our mission. You can contact our team at [email protected]

Yes, we still have our General License E from OFAC which allows us to raise and send funds for humanitarian efforts. We have no reason to believe this permission from OFAC would change in the future.

Yes. We pledge to keep informing you about the wellbeing of your sponsored child. We will also continue to be an access point for communication. 

Not at all. Our Tax-ID is 93-1148608. And we are still very proud to operate with great transparency for the good of children all around the world.

The only strict limitation we have right now is that we cannot send sponsorship money to Iran. We still have permission from the Department of Treasury to bypass sanctions and send humanitarian aid to Iran (General License E from OFAC). Additionally, we help vulnerable children all over the world each day because we believe education is important for all children.