On November 8, 2021, the Department of the Treasury’s Office of Foreign Assets Control published a new Syria-related frequently asked question. FAQ 934 provides that the United Nations and the US government are authorized to conduct stabilization and early recover-related activities and transactions that involve Syria pursuant to Syrian Sanctions Regulations (SySR) § 542.513 (United Nations) and § 542.211(d) and the general license § 542.522 (US government), subject to certain conditions. OFAC also provides that the SySR authorization extends to all employees, grantees and contractors carrying out official business for the United Nations or US federal government, including nongovernmental organizations (NGOs) and private companies that are acting as grantees or contractors, provided that these parties are able to provide a copy of their contract or grant with the United Nations/US government.
According to OFAC, NGOs not working on behalf of the UN or US government may be authorized under SySR § 542.516 to export or re-export certain services to Syria. OFAC also reports that non-US persons and entities are not at risk for US secondary sanctions if they engage in any activity that is authorized for US persons under the SySR.