On June 17, 2020, the US Department of Treasury’s Office of Foreign Assets Control announced the designation of 24 individuals and entities for providing significant supporting to the Government of Syria and participating in Syrian President Bashar al-Assad’s corrupt reconstruction efforts. These designations are the first made pursuant to the Caesar Syria Civilian Protection Act of 2019 (Caesar Act), named in honor of a photographer who documented the inhumane treatment of people in Syrian prisons, to target persons and entities that support the Assad regime’s mistreatment of the Syrian people. A majority, of OFAC’s designations are directed at private-public partnerships that seek to profit from the regime’s development of land that was confiscated from Syrian civilians during the Syrian civil war, in an effort to build five-star real estate and a luxury tourist development, aimed at ushering in the regime’s loyal demographic. Additionally, 9 of the 24 targets were designated due to their significant support to the Government of Syria.
Concurrent with the OFAC sanctions, the US Department of State has designated 15 people pursuant to Section 2 of Executive Order 13894, that focuses on those who attempt to disrupt a political solution or ceasefire for the Syrian conflict.
As a result of these sanctions, all US property for the 39 individuals and entities designated by OFAC and the Department of State is blocked, and all transactions and dealings with US persons are generally prohibited. Furthermore, any person who transacts with a designated person or entity may themselves be exposed to sanctions.