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1209. Even after the issuance of Syria General License (GL) 24 ("Authorizing Transactions with Governing Institutions in Syria and Certain Transactions Related to Energy and Personal Remittances"), may I still rely on existing sanctions authorizations for the provision of humanitarian aid?

Answer

Yes.  The authorization in GL 24 may overlap with the authorizations in existing GLs issued under the Syrian Sanctions Regulations (SySR), the Global Terrorism Sanctions Regulations (GTSR), and the Foreign Terrorist Organizations Sanctions Regulations (FTOSR), including:

  • transactions in support of certain nongovernmental organizations' activities (31 CFR §§ 594.520; 597.516; 542.516); 
  • official business of the U.S. Government (31 CFR §§ 594.518; 597.514; 542.522);
  • official business of certain international organizations (31 CFR §§ 594.519; 597.515; 542.513); and 
  • activities in certain economic sectors in specified areas of northeast and northwest Syria (31 CFR § 542.533). 

OFAC general licenses are "self-executing," meaning that persons who determine that certain activities are authorized under a GL may proceed without further assurance from OFAC.  Where multiple authorizations may apply, U.S. persons may rely on the broadest applicable authorization. 

With respect to transactions in support of certain nongovernmental organizations’ activities, U.S. depository institutions, U.S. registered brokers or dealers in securities, and U.S. registered money transmitters can process such transactions and may rely on the statements of their customers that such transactions are authorized unless they know or have reason to know a transaction is not authorized.  For more information, including an overview of authorized humanitarian activities in addition to GL 24, please review FAQs 231 and 938, and the OFAC Syria Compliance Communique.

Date Released
January 6, 2025