Frequently Asked Questions

1041 … Syria GL 22 is intended to improve the economic conditions in non-regime held areas of northeast and northwest Syria and support ongoing stabilization efforts in the region.  This new authorization also builds upon the Administration’s strategy to defeat ISIS in the region.  … What is the… Read more

1044 … Yes.  Transactions that are ordinarily incident and necessary to give effect to the activities authorized in Syria GL 22 are authorized.  Additionally, Syria GL 22 authorizes U.S. financial institutions to process transfers of funds related to authorized transactions and activities.  Such… Read more

1042 … No.   Syria GL 22 does not remove any sanctions on the Assad regime and excludes transactions involving any person, including the Government of Syria, whose property or interests in property are blocked pursuant to the Syrian Sanctions Regulations or the Caesar Syria Civilian Protection Act… Read more

1045 … For the purposes of Syria GL 22 , the Annex in GL 22 identifies areas of northeast and northwest Syria in which activities described in GL 22 are authorized as of May 12, 2022. Syria GL 22 does not authorize activities involving persons blocked pursuant to the Syrian Sanctions Regulations,… Read more

1043 … Syria GL 22 authorizes certain activities in non-regime held areas of northeast and northwest Syria in the following economic sectors:  agriculture; information and telecommunications; power grid infrastructure; construction; finance; clean energy; transportation and warehousing; water and… Read more

1046 … U.S. persons are not required to divest their holdings of CMIC securities during the relevant 365-day divestment period and may continue to hold such securities after the divestment period.  E.O. 13959, as amended, permits purchases or sales made solely to effect the divestment of CMIC… Read more

921 … The Protecting Europe’s Energy Security Act of 2019, 22 U.S.C. 9526 note, as amended (PEESA), requires the imposition of sanctions with respect to the provision of vessels engaged in specified activities for the construction of certain Russian energy export pipelines, including the Nord… Read more

922 … E.O. of September 17, 2021 provides for the imposition of menu-based sanctions on foreign persons determined by the Secretary of the Treasury, in consultation with the Secretary of State, to meet certain criteria under the order, including foreign persons determined to be responsible for or… Read more

923 … No.  Unless an entity is itself a sanctioned person (as defined in E.O. of September 17, 2021 ) and listed separately on OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List), it is not blocked pursuant to E.O. of September 17, 2021.  OFAC’s 50 Percent Rule does not apply… Read more

924 … No.  If a person is listed on OFAC’s Non-SDN Menu-Based Sanctions List (NS-MBS List) as subject to only one or more of the sanctions described in section 2(a)(i)(B) – (E) of E.O. of September 17, 2021, these non-blocking sanctions do not apply to an entity owned in whole or in part,… Read more