Financial Intelligence
Yes. Activities to support the rule of law, accountability, and transparency are broadly authorized 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 (NGO) activities (31 CFR §§ 594.520; 597.516; 542.516), official business of the U.S. Government (31 CFR §§ 594.518; 597.514; 542.522), and official business of certain international organizations (31 CFR §§ 594.519; 597.515; 542.513) by employees, grantees, or contractors thereof.
For example, the NGO activities general licenses authorize transactions in support of activities to support democracy building, including activities to support rule of law, citizen participation, government accountability and transparency, human rights and fundamental freedoms, access to information, and civil society development projects; and activities to support disarmament, demobilization, and reintegration (DDR) programs and peacebuilding, conflict prevention, and conflict resolution programs.
Yes. Syria General License (GL) 24 authorizes transactions in support of the sale, supply, storage, or donation of energy, including petroleum, petroleum products, natural gas, and electricity, to or within Syria. This may include, for example, the donation of gasoline to Syrian refineries, and power plants.
However, authorizations for this activity under the general license do not relieve persons from compliance with any other laws or requirements of other federal agencies or international organizations. For example, the export or reexport of petroleum, petroleum products, natural gas, and other commodities to Syria may require additional authorization from the Department of Commerce if such items are U.S.-origin or otherwise subject to the Export Administration Regulations (EAR).
No. SST restrictions on Syria remain in place.
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.
Yes. GL 24 authorizes transactions with governing institutions in Syria, with some conditions and exceptions, through July 7, 2025, even if a designated individual has a leadership role in that governing institution.
For example, if a company engaging in otherwise authorized activity needs to make a customs payment to a governing institution led by a blocked individual following December 8, 2024, that payment is authorized.
However, GL 24 does not authorize financial transfers to blocked persons other than for the purpose of effecting certain payments to governing institutions or for the purchase or receipt of permits, licenses, public utility services, or other public services in Syria. Please see FAQs 1206 and 1207.
GL 24 authorizes transactions under the Syrian Sanctions Regulations (SySR), the Global Terrorism Sanctions Regulations (GTSR), and the Foreign Terrorist Organizations Sanctions Regulations (FTOSR).
GL 24 generally authorizes the following transactions, with the exclusion of military or intelligence entities or those acting for or on their behalf:
- providing services to, or paying for services received from, Syrian governing institutions, such as the Ministry of Health, the Ministry of Education, or the Ministry of Water Resources, even if the ministry or leadership of the institution is blocked;
- payment of taxes, fees, or import duties to Syrian governing institutions, even if the ministry or leadership is blocked;
- purchase or receipt of permits, licenses, public utility services, or other public services;
- payment of salaries or wages to employees of governing institutions in Syria, provided such employees are not designated on OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List); and
- negotiating contracts or other agreements with Syrian governing institutions.
GL 24 does not authorize the following:
- any transaction involving Syrian military or intelligence entities or those acting for or on their behalf;
- importing Syrian petroleum or petroleum products into the United States;
- any transaction for or on behalf of the Government of the Russian Federation or the Government of Iran;
- any transactions related to the provision of Russian-origin or Iranian-origin goods, technology, software, funds, financing, or services;
- financial transfers to any person blocked pursuant to SySR, GTSR, and FTOSR, unless explicitly authorized;
- new investment in Syria, as defined in 31 CFR § 542.315, unless related to the provision of funds for salaries or wages of employees of governing institutions, provided such employees are not designated on OFAC’s SDN List; and
- unblocking of any property blocked pursuant to any part of 31 CFR chapter V.
Syrian governing institutions include departments, agencies, and government-run public service providers (including public hospitals, schools, and utilities) at the federal, regional, or local level in Syria following December 8, 2024, including entities involved with Hay’at Tahrir al Sham (HTS) across all geographic areas of Syria.
GL 24 does not authorize transactions involving military or intelligence entities, or any persons acting on behalf of such entities.
GL 24 is intended to ensure that sanctions do not impede essential governance-related services in Syria following the fall of Bashar al-Assad on December 8, 2024, including for the provision of public services or certain transactions related to energy or personal remittances. GL 24 complements OFAC's existing humanitarian-related authorizations by authorizing the following transactions, with some conditions and exceptions, through July 7, 2025:
- transactions with governing institutions in Syria following December 8, 2024;
- transactions in support of the sale, supply, storage, or donation of energy, including petroleum, petroleum products, natural gas, and electricity, to or within Syria; and
- transactions that are ordinarily incident and necessary to processing the transfer of noncommercial, personal remittances to Syria, including through the Central Bank of Syria.
GL 24 authorizes the foregoing under the Syrian Sanctions Regulations (SySR), the Global Terrorism Sanctions Regulations (GTSR), and the Foreign Terrorist Organizations Sanctions Regulations (FTOSR). It does not relieve any person from compliance with other Federal laws or regulations, including the International Traffic in Arms Regulations (ITAR) or the Export Administration Regulations (EAR) administered by the Department of Commerce.
For more information about the types of transactions covered by GL 24, see Frequently Asked Questions 1206, 1207, and 1208.