Primary Sanctions

The Syrian Sanctions Regulations (SSR) prohibit, among other things:

• the export, reexport, sale or supply, directly or indirectly, from the US or by a US person, wherever located, of any services to Syria; and
• the facilitation by a US person of transactions by a foreign person that the US person would otherwise be prohibited from engaging in under the SSR.

Secondary Sanctions

The Caesar Syria Civilian Protection Act of 2019, which went into effect on June 17, 2020, required the President to sanction foreign individuals and entities who knowingly:

• provides significant financial, material, or technological support to, or knowingly engages in a significant transaction with (i) the Government of Syria or a senior political figure; (ii) foreign military contractors, mercenaries, or paramilitary forces operating in a military capacity inside Syria for or on behalf of the Syrian, Russian, or Iranian governments; or (iii) a foreign person subject to sanctions under the OFAC’s Syria-related Sanctions program;
• sells or provides significant goods, services, technology, information, or other support that significantly facilitates the maintenance or expansion of the Syrian government’s domestic production of natural gas, petroleum, or petroleum products;
• sells or provides aircraft or spare aircraft parts that are used for military purposes in Syria to the Syrian government or foreign forces associated with the Syrian government; or
• provides significant construction or engineering services to the Syrian government.

The Commerce Department’s BIS is responsible for licensing exports to Syria under the Export Administration Regulations (EAR).  There is a general policy of denial for exports and reexports of US-origin goods, software, and technology to Syria.¹