Banks fear the "nuclear option" of secondary sanctions. Even when OFAC grants general licenses, a single clerical error can lead to a massive fine. To fix this, the Treasury needs to move beyond vague licenses.
They could establish a pre-approved "white list" of certified medical suppliers and logistics firms. If a bank processes a payment for a listed entity, they should receive a "safe harbor" guarantee—absolute immunity from penalties. This removes the guesswork that drives over-compliance.
Creating a dedicated payment channel, similar to the Swiss Humanitarian Trade Arrangement (SHTA), would help. A centralized clearing house could vet transactions before they hit the commercial banking system. When banks see that the US government has already blessed the specific transaction, the perceived risk vanishes.
Clearer, case-by-case pre-clearance for large shipments would also reduce friction. Currently, the burden of proof falls on the bank. Shifting that burden to a specialized OFAC review desk for humanitarian goods would get medicine moving faster.
