June 6, 2024

OFAC amends the Syria Sanctions Regulations and issues new and updated general licenses and FAQs

On June 5, 2024, the U.S. Department of the Treasury’s Office of Foreign Assets Control amended the Syrian Sanctions Regulations (“SySR”), 31, CFR Part 542, to, among other things, implement relevant provisions in Executive Order 13608 that enable restrictions upon foreign persons that are determined to be sanctions evaders with respect to Syria and Iran. The amendment also incorporates certain prohibitions in the Syria Human Rights Accountability Act (“SHRAA”), the Countering America’s Adversaries Through Sanctions Act (“CAATSA”) and the Caesar Syria Civilian Protection Act of 2019 (a/k/a the Caesar Act), which is aimed at preventing the Assad regime from obtaining resources needed to support the repression of the people of Syria.

In addition to new prohibitions, the amendment incorporates the authorizations in a new general license and adds relevant definitions and interpretations.  OFAC also incorporates the provisions in General License 22, which had previously been issued only on OFAC’s website, into the SySR.  As a result, General License 22, which authorizes activities in certain economic sectors in non-regime held areas of Northeast and Northwest Syria, will be removed from the website upon publication of the rule.  Because of this, OFAC is publishing a list of areas in northwest and northeast Syria where GL 22 activities are permitted – a list that had previously only existed as an annex to GL 22.  Finally, OFAC updated six general licenses that authorize various actions that would otherwise be prohibited by the SySR, including certain activities by nongovernmental organizations (“NGOs”) and international organizations.

OFAC also issued new Frequently Asked Question 1180 to provide an overview of changes resulting from the new amendments.  OFAC also amended several FAQs (FAQs 205, 231, 232, 934, and 938) to reflect the new amendments to the SySR.

OFAC Recent Action | SySR Amendments – Final Rule | List of Areas in NE and NW Syria – Final Rule | FAQ 1180 | Updated FAQs