oidg
Humanitarian Aid Initiative in Iran
situation
Oxford International Development Group (OIDG), known for its expertise in OFAC-licensed health diplomacy projects, embarked on a
groundbreaking humanitarian initiative aimed at alleviating the healthcare crisis in Iran. This crisis was significantly worsened by sanctions
and governmental policy inadequacies, leading to a dire shortage of critical medical supplies in Iranian hospitals. The project was uniquely
structured to utilize frozen Iranian funds, facilitating the procurement and delivery of these essential supplies.
task
OIDG, leveraging its 15-year experience in health diplomacy, was tasked with navigating the intricate legal and operational landscape of
international sanctions. The objective was to establish a legal and financial framework that could securely channel the frozen assets into a
humanitarian aid stream, without breaching OFAC regulations or international sanctions. This required close collaboration with various
stakeholders, including the Iranian Critical Care Society (ICCS), the Ministry of Foreign Affairs, the Sultanate of Oman, and crucially, obtaining
and adhering to specific OFAC licenses (IA-2021-373200-1).
actions
Under the legal and compliance oversight of GSI PLLC, led by Chad Altieri, Esq., and supported by a meticulously assembled team, OIDG
undertook several strategic actions:
1
Legal Compliance & Licensing: OIDG secured the necessary OFAC License IA-2021-373200-1 and actively engaged with
OFAC and the U.S. Department of State to ensure the project's full compliance with U.S. sanctions laws, including Executive
Order 13902 and the Iranian Transactions and Sanctions Regulations (ITSR).
2
Financial Framework Establishment: A receivership clearing account was set up in Ahli Bank, Oman, to manage the frozen
assets. This structure was carefully designed to adhere to AML, CTF, and KYC protocols, ensuring the transparent and
compliant flow of funds.
3
Operational Execution: Through strategic partnerships and a robust operational plan, OIDG coordinated the procurement,
shipping, and distribution of medical supplies. This included direct collaborations with U.S. manufacturers, adhering to
export controls, customs regulations, and ensuring quality standards under the Drug Quality Security Act (DQSA).
4
Comprehensive Compliance Program: A detailed compliance framework was developed, encompassing global operations,
export-import management, risk assessment, know your customer (KYC) procedures, food supply guidelines, security
policies, anti-bribery and corruption manuals, and anti-money laundering and counter terrorism finance (AML/CTF)
protocols. This program was essential for maintaining integrity and transparency throughout the project's lifecycle.
5
Collaborative Team Structure: The project was supported by a diverse team of professionals, including strategic managers,
compliance officers, legal advisors, financial managers, supply chain experts, and field operation managers. Regular training
and adherence to best practices ensured the project's alignment with humanitarian goals and compliance standards.
results
The OIDG initiative successfully channeled billions in frozen Iranian funds to deliver vital medical supplies to Iranian hospitals, directly
addressing the healthcare crisis. This project not only showcased the United States' commitment to global health and humanitarian aid but
also served as a pioneering model for utilizing frozen assets for humanitarian purposes. It improved healthcare infrastructure in Iran,
fostered goodwill, and potentially laid the groundwork for future diplomatic relations.
Moreover, the initiative demonstrated OIDG's adherence to U.S. laws and international regulations, enhancing the credibility of U.S. entities
in conducting lawful international assistance. It also facilitated a unique platform for diplomatic engagement, setting a precedent for
transparency, legal compliance, and operational excellence in humanitarian aid projects.
In conclusion, the humanitarian project stands as a testament to the power of innovative legal and financial frameworks, strategic
collaboration, and a comprehensive compliance program in overcoming the challenges of delivering aid within a sanctioned environment.