On January 21, 2014, World Vision United States (World Vision), a subsidiary of World Vision International (WVI), submitted a grant application to USAID to carry out their proposed Blue Nile Recovery Program to provide food security, sanitation equipment and health services to the conflict affected areas in the Blue Nile region of Sudan. World Vision was subsequently awarded a grant of $723,405 by USAID to carry out the program. On February 1, 2014, World Vision entered into an agreement with Islamic Relief Agency (ISRA) whereby ISRA would provide humanitarian services to certain parts of the Blue Nile Region on behalf of World Vision. Prior to this, World Vision had worked with ISRA on several projects from 2013 through 2014.
During the summer of 2014 – while the Blue Nile Recovery Program was in full swing – World Vision entered into talks with the International Organization for Migration (IOM) to work jointly on a separate humanitarian project in Sudan. During these conversations, IOM performed its due diligence by conducting a routine vetting of World Vision and its partners which, at the time, included ISRA. During this vetting procedure, IOM discovered that ISRA was in fact listed on the sanctioned entity list. IOM subsequently reached out to the Office of Foreign Assets Control (OFAC) Compliance Team to confirm that ISRA was indeed a sanctioned entity. Following OFAC’s confirmation that ISRA was indeed a sanctioned entity, IOM rejected World Vision’s offer to work together on a subsequent humanitarian project.
In late September 2014, World Vision’s legal department was notified of ISRA’s potential status as a sanctioned entity. World Vision immediately ceased all payments to ISRA and began investigating whether ISRA was indeed a sanctioned entity. On November 19, 2014, World Vision sent a letter to OFAC requesting clarification of ISRA’s status. The letter also included a request for a temporary license to complete the existing contract with ISRA, despite their status, in the event that ISRA was indeed a sanctioned entity.
According to World Vision, OFAC took longer than expected to respond. During this time, World Vision’s field office in Sudan reported that ISRA and the Sudanese government were applying intense pressure on it to pay money owed for services performed. On January 20, 2015, two months after World Vision submitted its request for clarification to OFAC, World Vision General Counsel sent an email to OFAC informing them of World Vision’s intent to resume its work with ISRA in a week’s time unless it received a response from OFAC confirming ISRA’s sanctioned status.
On January 23, 2015, Treasury responded to World Vision’s November inquiry and informed it that ISRA is indeed a sanctioned entity. Furthermore, in the same letter OFAC denied World Vision’s request for a license to transact with ISRA, stating that authorizing further activities would be “inconsistent with OFAC policy.”
On February 19, 2015, World Vision again requested a license to transact with ISRA in order to pay them $125,000 for services rendered. In its request, World Vision stressed that it could face severe legal consequences and even expulsion from Sudan if it did not pay ISRA the monies owed. On May 4, 2015, the Obama Administration’s State Department recommended OFAC grant World Vision’s request for a license to pay ISRA $125,000 in monies owed. The following day, OFAC granted World Vision a specific license to pay ISRA $125,000 only for services rendered. On May 14, 2015, OFAC sent World Vision a “Cautionary Letter” notifying it that the transactions they engaged in with ISRA appears to have violated the Global Terrorism Sanctions Regulations, 31 C.F.R. part 594, in direct opposition of U.S. law and international sanctions.
