Tasnim News Agency [CC BY 4.0], via Wikimedia Commons

November 16, 2017; Al Jazeera

With major faults covering some 90 percent of the country, Iran often experiences earthquakes. The 7.3 magnitude earthquake last Sunday on Iran’s border with Iraq was the deadliest in the world this year to date. At least 530 lives were lost, 7,460 people injured, 12,000 homes were destroyed, and 15,000 more were damaged. The Kermanshah province was the area hardest hit, but cities as far away as Tehran and Baghdad felt the tremors.

Around the world, the Iranian diaspora and many others also felt the shaking, and some of them were compelled to respond to the emergency. Kianoush Rostami, the Iranian Rio 2016 Olympic weightlifter, put his gold medal up for auction via Instagram to raise money for the victims.

Al Jazeera’s Ted Regencia shares stories about good intentions hitting frustrating barriers. Members of the Facebook group Persian Americans (65,827 followers) gave $80,000 within the first few hours of their Facebook-based appeal, and by Wednesday, the sum exceeded $200,000. Facebook initially informed the group’s leader that the funds would be held until the US Department of Treasury authorized disbursement. On Thursday, Facebook dismantled the group’s fundraising page, informing the leader “personal fundraisers are not eligible to receive funds for nonprofits.”

An Iranian-American journalist used the YouCaring crowdfunding site to raise support for the earthquake survivors. YouCaring removed her page after she raised $2,000 in the first 30 minutes “because the country you provided is part of an embargoed region.”

“The United States Treasury Department does not allow our platform to disburse funds directly to, or be routed by proxy to a state or person that is currently located in an embargoed region,” the letter read.

Here is a page with dozens of links having to do with the current Iran sanctions, offering guidelines, licenses, licensing policies, executive orders, statutes, rules and regulations, and even the United Nations Security Council resolutions. This page has links to all the US Sanctions Programs and Country Information, from Belarus to Zimbabwe. It is one thing to spontaneously raise support for those in urgent need around the world. It is something entirely different to comprehend the level of complexity involved in winning the authorization to get the money and relief supplies to the intended beneficiaries. We would see the same stories of donor frustration if the emergency were in Sudan or Venezuela.

The Office of Foreign Assets Control (OFAC) of the US Department of Treasury administers and enforces these economic and trade sanctions. Executives from Facebook, Google, and Twitter just appeared before Congress for a public reckoning for their tools being used to deploy a Russian misinformation campaign during the US 2016 election. Facebook and crowdfunding sites like YouCaring are justifiably cautious about the risks of violating US foreign policy and national security goals against targeted countries, terrorists, narcotics traffickers, and those involved in the proliferation of weapons of mass destruction. No one wants to receive administrative subpoenas for being on the wrong side of these issues with the OFAC.

Ted Regencia points out that the OFAC does make provisions for channeling humanitarian relief to sanctioned countries such as Iran via OFAC-approved NGOs. The problem is that the very NGOs most capable of accomplishing the most good and raising the most money are not authorized by the OFAC to do so.

Transfers of personal remittances “to assist a family member or a friend” is also allowed provided that the payment is processed through a third-country financial institution. However, experts say foreign banks are often reluctant to process such donations out of fear of potential fines and other complications.

US-based donors are not permitted to send funds directly, even to charitable and humanitarian groups already on the ground in Iran, such as the Iranian Red Crescent, a group with a wide network and presence in many areas.

Regencia notes that the Iranian Red Crescent Society is not an OFAC-approved NGO. Formed in 1922, a member of the International Federation of Red Cross and Red Crescent Societies, this NGO has already reportedly “reached 90 percent of the areas affected by the quake.”

What are the OFAC-approved charities? Moms Against Poverty, Child Foundation, Children of Persia, and Relief International. These are the four nonprofits listed by Al Jazeera, Newsweek, USA Today, and presumably by most everyone else. Their annual expense budgets, according to their latest Form 990 filings on GuideStar, are MAP $727,000; Child Foundation $2.7 million; Children of Persia $145,000; and Relief International $28 million (showing a $2.3 million deficit in 2015, and a $3.4 million deficit in 2014). Here is the Iranian Red Crescent Society’s lengthy 2015 annual report for comparison.

There is a serious problem with this picture. I am sure these four charities mean well, and it no doubt took some doing to be authorized by the OFAC, but the be the primary channel for humanitarian aid to a country in desperate need is very likely a scenario they did not anticipate or wish upon themselves. Incompetence can cost lives. Every hour counts after an earthquake.

US sanctions also influence the behavior of foreign banks.

Ellie Geranmayeh, an Iran expert at the European Council on Foreign Relations, said that “it is virtually impossible” to donate directly from Britain to humanitarian relief organizations already in Iran helping with earthquake victims. Geranmayeh cited “over compliance” of the UK banks has prompted them to “refuse to transact to accounts with ‘Iran’ in the title.”

“The process is everything it’s not meant to be when responding to a disaster: Slow, complex and at times impossible,” she told Al Jazeera.

There have been exceptions to the rule. Following the 2012 earthquakes in Iran, the Obama administration temporarily lifted sanctions to permit donations to US NGOs for a period of 45 days, which the Obama extended permanently in 2013. But, of course, that was then, and this is now.—Jim Schaffer