On May 12, 2022, the Department of the Treasury’s Office of Foreign Assets Control issued Syria General License 22 to authorize activities in certain listed economic sectors in non-regime held areas in northeast and northwest Syria, which would have otherwise been prohibited by the Syrian Sanctions Regulations, 31 CFR part 542 (SySR). The authorizations extend to sectors such as agriculture, information and telecommunications, health series, and education, among others. The general license also allows for the purchase of Syria-origin petroleum products for use in Syria if they involve one of the economic sectors listed in GL 22. OFAC urged the public to see §542.510 of the SySR for a general license authorizing the exportation or reexportation of certain items and services to Syria.
OFAC also published several new frequently asked questions (1041 -1045) to provide additional guidance regarding the provisions in GL 22. In addition, OFAC amended FAQ 884 to clarify that non-US persons, including nongovernmental organizations and foreign financial institutions, will generally not risk exposure to secondary sanctions under the Caesar Syria Civilian Protection Act of 2019 if the activities being performed were activities that US persons would be authorized to perform under a general license pursuant to the SySR.