Taliban administration since 2021. Healthcare infrastructure largely collapsed (per HRW 2026 — 400+ health facilities closed).
Sanctions overlay (as of May 2026)
Taliban remains historically designated under multiple US OFAC sanctions; delisting status unclear.
No specific veterinary-pharmaceutical general license publicly identified.
Afghan central bank assets remain frozen; banking system largely non-functional for international transactions.
DOJ's May 2025 memorandum prioritizes sanctions evasion enforcement.
Multi-distributor permissibility
GAP / NOT RECOMMENDED Taliban-era commercial law in flux; pre-2021 commercial law contemplates registered agents but enforcement is de facto unavailable. Multi-distributor question is moot given JAPFA should not enter market.
Voidance risks
GAP / SEVERE Court system is restructured under Taliban administration; pre-2021 contract precedent of uncertain weight; Sharia-compliance review likely. Even valid contracts face unenforceability through banking-system collapse and sanctions overlay.
JAPFA recommendation
Do NOT export to Afghanistan without (i) written OFAC pre-clearance opinion AND (ii) US sanctions counsel review of every transaction. Reputational risk significant. Consider blanket exclusion from territory grants in any distribution agreement.
Signed contracts in this country
ZALAND SARSABZ LTD
Counterparty
ZALAND SARSABZ LTD
Effective
1 April 2024
Term
Indefinite
Score / grade
53 / 100D
Template
Standard Vaksindo
Signing order anomaly
Counterparty signed first (4 May before 10 May Vaksindo)
Authorized Products (current LOA)
LOA dated 8 May 2024, valid until 1 April 2027 (7 SKUs, blanket unilateral JAPFA authorization). 20% annual upward revision. 3-year totals: Y1 USD 310,200 · Y2 USD 372,120 · Y3 USD 446,544.
#
Product
Strain
Dose
Annual vol
CIF USD
1
Vaksimune IB
Infectious Bronchitis
1000-dose vial
20,000
1.45
2
Vaksimune ND LS
Newcastle Disease LaSota
1000-dose vial
20,000
1.32
3
Vaksimune ND LS IB
Newcastle Disease LaSota + IB combined
1000-dose vial
20,000
1.70
4
Vaksimune ND Clone
Newcastle Disease Clone
1000-dose vial
6,000
1.80
5
Vaksimune IBD L
Infectious Bursal Disease Live
1000-dose vial
20,000
1.76
6
Vaksimune ND IB Inaktif
ND + IB Inactivated
1000-dose vial
4,500
17.00
7
Vaksimune ND L IBPlus
ND Live IB Plus
1000-dose vial
4,500
18.00
Art. 34 verbatim
Governing law:"The Parties agree that This Agreement shall be governed by and construed in accordance with, and the legal relations between the Parties hereto shall be determined in accordance with, the laws of the Republic of Indonesia, without regard to any laws relating to conflict of laws."
Dispute:"Any dispute arising between the Parties in relation with this Agreement, shall be settled among the Parties in good faith within thirty (30) business days since the date of the dispute. Failing that, the Parties agree to bring the dispute to BANI or in accordance with the arbitration rules of the Singapore International Arbitration Centre ('SIAC Rules')."
Top 3 issues
Hybrid BANI/SIAC dual forum defect at Art. 34.2 (same as 7 other portfolio contracts).
Counterparty signed first (4 May before 10 May Vaksindo).
Afghan sanctions / Taliban exposure.
Country watch items
Hybrid forum defect + sanctions exposure
Severity: HIGH.
Art. 34.2 confirmed as hybrid BANI/SIAC defect (governing_law_cat A clean Indonesian; forum_cat D hybrid). Same defect as 7 other portfolio contracts.
Action: Sanctions counsel review (Afghan / Taliban OFAC SDN + EU + UK + UN 1988 Sanctions Committee); apply Amendment No. 1 (single SIAC Singapore + KUHPerdata 1266/1267 waiver + CISG exclusion).