Yes. The general license at § 542.513 of the Syrian Sanctions Regulations (SySR) authorizes, subject to certain conditions, the United Nations, including its Programmes, Funds, and Other Entities and Bodies, as well as its Specialized Agencies and Related Organizations, The International Committee of the Red Cross and the International Federation of Red Cross and Red Crescent Societies; and The Global Fund to Fight AIDS, Tuberculosis, and Malaria, and Gavi, the Vaccine Alliance and their employees, contractors, or grantees to engage in all transactions and activities in support of their official business in Syria, including any stabilization and early recovery-related activities and transactions in support of their official business. This authorization applies to all employees, grantees, and contractors carrying out the official business of the United Nations, its Specialized Agencies, Programmes, Funds, and Related Organizations, including nongovernmental organizations (NGOs) and private sector entities that are acting as grantees or contractors.
In addition, § 542.211(d) and the general license at § 542.522 exempt and authorize, respectively, subject to certain conditions, the U.S. government and its employees, grantees, or contractors to engage in all transactions in support of their official business in Syria, including any stabilization and early recovery-related activities and transactions in support of their official business. This exemption and authorization apply to all employees, grantees, and contractors carrying out the official business of the U.S. government, including NGOs and private sector entities that are acting as grantees or contractors.
For NGOs that are not acting as grantees or contractors of the aforementioned international organizations or the U.S. government, please see the general license at § 542.516 for authorizations under the SySR related to certain transactions in support of certain NGO activities.
Additionally, organizations and entities may also rely on the authorization in § 542.533 for activities in certain economic sectors in non-regime held areas of Northeast and Northwest Syria.
Separately, non-U.S. persons, including NGOs, private sector entities, and foreign financial institutions facilitating or assisting in the aforementioned activities, do not risk exposure to U.S. secondary sanctions pursuant to the Caesar Syria Civilian Protection Act of 2019 for engaging in the above activities for which a U.S. person would not require a specific license. Please see 31 CFR § 542.414 and FAQ 884 for additional information.
Please note that this guidance does not apply to transactions and activities that may be subject to sanctions under other sanctions programs administered by OFAC (e.g., transactions with persons blocked under OFAC’s counterterrorism authority (E.O. 13224, as amended) or OFAC’s Syria-related authority (E.O. 13894)), unless exempt or otherwise authorized by OFAC.
Updated: June 05, 2024