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Medicine and medical supplies

· Helfen statt Blockieren editorial team

Medicines, medical technology and spare parts for hospitals are expressly permitted or licensable under most sanctions programmes. Whether they arrive is often decided by banks, manufacturers and forwarders who shy away from the risk.

What is blocked

  • Cuba: Since 21 October 2019 goods from third countries need a US licence if more than 10 percent of their value is of US origin; the threshold used to be 25 percent1.
  • Cuba: US exports of medicines and medical supplies are allowed, but only with a specific licence and, except for donations to non-governmental organisations, with on-site verification of their use2.

What is expressly allowed

  • UN: Resolution 2664 of 9 December 2022 makes clear that funds and services for humanitarian aid and basic human needs are not covered by UN asset freezes. 14 states voted in favour, India abstained3.
  • US: On 20 December 2022 the Treasury issued general licenses in programmes that had no humanitarian exception, among others for agricultural commodities, medicine and medical devices4.
  • US and Cuba: the 1992 law prohibits restricting exports of medicines and medical equipment to Cuba, except where misuse, re-export or use for biotechnology is likely2.

What still does not arrive

  • Iran: In 2019 Human Rights Watch described excessive caution by banks and pharmaceutical companies as a major reason for missing medicines. A European manufacturer stopped selling a special dressing for children with epidermolysis bullosa5.
  • Cuba: OFAC licences for spare parts take six to twelve months, according to information given to the Special Rapporteur6.

Documented examples

  • IranThe children’s cancer charity MAHAK lacked three chemotherapy drugs, all on the WHO list of essential medicines5. In autumn 2020 insulin was rationed; CIDRAP names the US sanctions on 18 banks of 8 October 2020 as a possible cause, but also smuggling, corruption, and price and quality issues7.
  • North KoreaExemptions for aid supplies took 99 days on average in 2018 and 15 days in 2019. The affected categories included syringes, needles and wheelchairs8.
  • Cuba69 percent of medicines are inaccessible to the population, according to information given to Alena Douhan6.

Counterpoints: why states impose sanctions

  • Human Rights Watch states that sanctions do not diminish the human rights obligations of the targeted state, and recommends that Iran combat corruption and misuse of public funds5.
  • Cuba: The US government justifies its measures with the policies of the Cuban government. Executive Order 14380 of 29 January 2026 cites support for hostile states and groups and the human rights record9.
  • Iraq: A widely cited 1999 survey claiming that child mortality had doubled under sanctions was manipulated by the government of the time, according to a 2017 study at the London School of Economics. Figures from affected states need independent checking10.

Figures marked “according to information given to” are not the cited body’s own measurements but information presented to it.

This page is information, not legal advice. It reports what authorities, courts, governments and organisations decide and say; the views of the side imposing measures and of the side affected stand side by side. “Helfen statt Blockieren” is non-partisan. Please report errors to info@aciel-martinez-poll.com.

Sources

  1. Kelley Drye, “BIS tightens Cuba restrictions, lowers de minimis threshold to 10 percent (Federal Register Doc. 2019-22876)”, 21 Oct 2019. https://www.kelleydrye.com/viewpoints/blogs/trade-and-manufacturing-monitor/bis-tightens-cuba-restrictions-lowers-de-minimis-threshold-to-10-percent
  2. US Congress, 22 U.S.C. § 6004 (Cuban Democracy Act 1992), text at Cornell LII, Exports of medicines and medical supplies, subsections (c) and (d), 3 Nov 2026. https://www.law.cornell.edu/uscode/text/22/6004
  3. UN Security Council, press release SC/15134 (9214. meeting), Report on the adoption of Resolution 2664 (2022), 9 Dec 2022. https://press.un.org/en/node/311942
  4. US Treasury, press release JY1175, “Treasury Implements Historic Humanitarian Sanctions Exceptions”, 20 Dec 2022. https://home.treasury.gov/news/press-releases/jy1175
  5. Human Rights Watch, ““Maximum Pressure”: US Economic Sanctions Harm Iranians’ Right to Health”, 29 Oct 2019. https://www.hrw.org/report/2019/10/29/maximum-pressure/us-economic-sanctions-harm-iranians-right-health
  6. OHCHR, Special Rapporteur Alena Douhan, Preliminary findings of the visit to Cuba, end of mission statement, 11 to 21 November 2025, 21 Nov 2025. Many figures there are marked “reportedly”, i.e. based on information presented to her. https://www.ecoi.net/en/file/local/2133521/20251121-eom-stm-cuba-sr-negative-impact-unilateral-en.pdf
  7. CIDRAP, University of Minnesota, “Insulin shortages have plagued Iran for months”, December 2020. https://www.cidrap.umn.edu/news-perspective/2020/12/insulin-shortages-have-plagued-iran-months
  8. 38 North, “The Human Costs of UN Sanctions and Funding Shortfalls for Humanitarian Aid in North Korea”, 22 Aug 2019. https://www.38north.org/2019/08/parkkimjong082219/
  9. White House, Federal Register 91 FR 5085, “Executive Order 14380: Addressing Threats to the United States by the Government of Cuba (unterzeichnet 29.1.2026)”, 3 Feb 2026. https://www.govinfo.gov/content/pkg/FR-2026-02-03/html/2026-02250.htm
  10. London School of Economics, on Dyson and Cetorelli, BMJ Global Health 2017, “Iraqi government misreported child mortality, LSE research finds”, 25 Jul 2017. https://lse.ac.uk/News/Latest-news-from-LSE/2017/07-July-2017/Iraqi-government-misreported-child-mortality-LSE-research-finds.aspx

All online sources accessed on 3 November 2026.

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