On September 30, 2020, the US Department of the Treasury’s Office of Foreign Assets Control designated three individuals and thirteen entities for supporting the brutal Bashar al-Assad regime, in an effort to bring a peaceful resolution to the conflict in Syria. OFAC sanctioned a regime-connected Syrian businessman Khodr Taher Bin Ali and his network of businesses that generate revenue for the regime, pursuant to Executive Order 13582 for sponsoring or providing financial support for the Government of Syria, and being owned or controlled by Taher. OFAC also designated two key officials in the Assad regime. The current head of the Syrian General Intelligence Directorate (GID), one of Syria’s four intelligence agencies, was designated pursuant to EO 13572 for being a senior official in the GID. OFAC also designated the Governor of the Central Bank of Syria, pursuant to EO 13573 for being a senior official in the Government of Syria, and pursuant to EO 13852 for sponsoring or providing financial support to the Government of Syria.
As a result of these designations, all US property belonging to these individuals and entities is blocked, and all transactions and dealings with them are generally prohibited. In addition, any entity in the US that is owned fifty percent or more by the sanctioned entity is also blocked. OFAC also amended the Syrian Sanctions Regulations, 31 CFR Part 542, issuing General License 20 to authorize wind down transactions with newly designated Emma Tel LLC, a telecommunications provider in Syria, and one of the businesses that are owned or controlled by Khodr Taher Bin Ali, discussed above. GL 20 authorizes transactions with Emma Tel or any entity that Emma Tel owns a fifty percent or greater interest, until December 30, 2020.
OFAC also issued Frequently Asked Question no. 841 to clarify the provisions of GL 20, emphasizing among other things, that US and non-US persons who are unable to wind down transactions with Emma Tel by the December 30, 2020 deadline are encouraged to seek guidance from OFAC.