On December 22, 2020, the US Department of the Treasury’s Office of Foreign Assets Control designated a husband and wife, who are both senior officials in the Syrian government, along with several the business entities they own or control. OFAC also added the Central Bank of Syria (CBoS) to the Specially Designated Nationals and Blocked Persons List (SDN List), and identified property belonging to previously sanctioned individuals. In total, OFAC designated two individuals and nine entities, pursuant to Executive Order 13573, and identified the CBoS as part of the Government of Syria, pursuant to Executive Order 13582, and Syrian Sanctions Regulations (SySR), 31 CFR Part 542. These sanctions were issued in an effort to discourage future investment in areas of Syria controlled by the Assad regime, end the regime’s atrocities against the Syrian people, and encourage the regime to conform with the UN Security Council Resolution 2254.
The State Department concurrently designated six Syrian people pursuant to Section 2 of EO 13894, “Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Syria.”
OFAC also stressed that the US remains committed to helping the Syrian people, and reminded humanitarian organizations to consult previously-issued OFAC guidance before providing aid to this region, and issued further humanitarian-related guidance by releasing new Frequently Asked Questions 866, 867, and 868. FAQ 866 addresses the various prohibitions that apply to the CBoS, while emphasizing that all property and interests in property that are connected to the bank remain blocked, and general and specific licenses continue to apply when providing humanitarian assistance that may involve CBoS. FAQ 867 provides a detailed explanation of the various types of transactions and humanitarian assistance that US and non-US persons can still provide to the people of Syria. Finally, FAQ 868 specifically addresses whether non-US persons will face sanctions if they engage in humanitarian transactions with Polymedics LLC and Letia Company, two entities included in the recent OFAC designations. OFAC explains in FAQ 868, that non-US persons will not risk exposure to sanctions when engaging with both entities, as long as the activity is exempt from SySR regulations or authorized for US persons by a general license in the SySR.
In summary, all US property belonging to the sanctioned 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 or individual is also blocked.