Yes. The new Syria Executive order, Executive Order 13582, does not prohibit U.S. persons from engaging in transactions ordinarily incident to travel to or from any country, including importation of accompanied baggage for personal use, maintenance within any country including payment of living expenses and acquisition of goods or services for personal use, and arrangement or facilitation or such travel including nonscheduled air, sea, or land voyages.
For the purposes of OFAC Syria General License No. 4A, "items subject to the EAR" is defined at § 734.3 of the Export Administration Regulations ("EAR"), 15 C.F.R. Parts 730-774.The EAR are administered by the U.S. Department of Commerce, Bureau of Industry and Security ("BIS"). Note that BIS maintains authority to license exports and reexports to persons in Syria whose property and interests have been blocked pursuant to Executive Order 13606 (the “GHRAVITY E.O.”). For further guidance regarding the exportation or reexportation of items to Syria, please consult the EAR. You may also wish to review the BIS Syria Web page or contact BIS by phone at (202) 482-4252.
The export or reexport of food or medicine that is subject to the EAR to the Government of Syria, other than medicine on the Commerce Control List that has not been licensed by BIS for export or reexport to Syria, does not require a specific license from OFAC.
As set forth in the EAR, which implements the Syria Accountability and Lebanese Sovereignty Restoration Act of 2003 ("SAA") and Executive Order 13338 of May 11, 2004, BIS does not require a license for the export or reexport of "EAR99" food and medicine; accordingly, EAR99 food and medicine can be exported or reexported to the Government of Syria on a "NLR" ("No License Required") basis, under the regulations administered by BIS.
Additionally, as set forth in the EAR, a BIS license is required for the export or reexport of medicine that is on the Commerce Control List ("CCL medicine"). If BIS has licensed the export or reexport of CCL medicine to the Government of Syria, no specific OFAC license is required.
General License No. 4A only applies to items that are subject to the EAR, as set forth in 15 C.F.R. § 734.3. If a foreign-made item located abroad is not subject to the EAR based on the regulations administered by BIS, the exportation or reexportation of such items by U.S. persons to the Government Syria and the reexportation of services incident to an exportation of such items to Syria are not authorized by General License No. 4A. Because Executive Order 13582 generally prohibits U.S. persons from engaging in transactions with the Government of Syria and separately prohibits the exportation, reexportation, sale, or supply, directly or indirectly, by a United States person, wherever located, of any services to Syria, such transactions remain prohibited.
I want to support non-governmental organizations (NGOs) that help the Syrian people. How can I do this while staying in compliance with sanctions?
U.S. persons may donate funds to and raise funds on behalf of U.S. and third-country NGOs that engage in authorized activities in Syria (please see § 542.516 of the Syrian Sanctions Regulations for the full list of authorized activities). U.S. persons can also donate humanitarian goods like food and medicine to the Syrian people.
Please note that the Department of Commerce, Bureau of Industry and Security (BIS) has jurisdiction over the export or reexport to Syria of items (commodities, software, and technology) subject to the Export Administration Regulations (EAR), 15 CFR parts 730-774, including items that are located in the United States and certain foreign-origin items located abroad that contain a certain de minimis level of U.S.-origin content that require a license for export to Syria. BIS maintains comprehensive restrictions on the export or reexport to Syria of items subject to the EAR. These restrictions apply to all items subject to the EAR apart from food and medicine that are designated as “EAR99.” These EAR restrictions apply to both U.S. persons and non-U.S. persons. As a general matter, we recommend that both U.S. and non-U.S. persons contact BIS directly with any questions relating to Syria restrictions under the EAR.
U.S. person individuals are not authorized to transfer funds directly to Syria for the purpose of charitable donations, absent a specific license from OFAC.
U.S. financial institutions, as defined in 31 CFR 542.321, are authorized to process transfers of funds to or from Syria on behalf of U.S. and third-country nongovernmental organizations (NGOs), in support of the authorized activities described in the NGO General License (GL) at § 542.516 of the Syrian Sanctions Regulations (SySR).
The SySR NGO GL does not authorize funds transfers with knowledge or reason to know the intended beneficiary is a blocked person other than the Government of Syria as defined in § 542.308(a), except for limited transactions ordinarily incident and necessary to the authorized activities described in § 542.516
If you have specific questions about donating funds to Syria, please contact OFAC.
Updated: June 05, 2024
As an individual, may I transfer funds directly to Syria in support of authorized NGO activities under General License No. 11?
No. Only U.S. depository institutions, U.S. registered brokers or dealers in securities, and U.S. registered money transmitters are authorized to process such transfers of funds, and only on behalf of U.S or third-country NGOs. Although individuals may not transfer funds directly to Syria in support of authorized NGO activities under General License No. 11, please note that, pursuant to General License No. 6, individuals may send noncommercial, personal remittances to individuals in Syria provided that, among other things, the Government of Syria is not involved. However, General License No. 6 provides that “noncommercial, personal remittances” do not include charitable donations of funds to or for the benefit of any entity or funds transfers for use in supporting or operating a business. Please see General License No. 6 for further details.
If you wish to donate funds in support of humanitarian work in Syria, you may do so by transferring funds to an NGO to support its work in Syria. If you wish to send a charitable donation directly to Syria, you must apply for specific authorization to transmit such funds.
The United States has sanctioned the Syrian government, including the Central Bank of Syria, senior Syrian government officials, and individuals and entities supporting the Assad regime and/or responsible for human rights abuses in Syria, in order to reinforce the President’s call that Bashar al-Assad step down and to disrupt the Assad regime’s ability to finance its campaign of violence against the Syrian people. In addition, Treasury has sanctioned the Commercial Bank of Syria and a number of other entities under Executive Order 13382, an authority that targets proliferators of weapons of mass destruction (WMD) and their supporters. Over the years Treasury has applied a broad range of sanctions using several different authorities and Executive orders (E.O.s), including counter-terrorism (E.O. 13224), human rights abuses (E.O. 13572), and non-proliferation (E.O. 13382). The United States has also prohibited the exportation of services to Syria, and there have long been legal restrictions on what goods U.S. persons can export to Syria.
These sanctions mean that U.S. persons are not permitted to do business with individuals or entities on OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List), or with any entity 50 percent or more owned by an Specially Designated National (SDN), unless exempt or authorized by OFAC through a general or specific license.
How can I help the Syrian people while making sure to abide by the U.S. sanctions?
Recognizing that the Syrian people need many critical services and goods, OFAC has issued several general licenses that, among other things, allow all U.S. persons to send non-commercial, personal remittances to Syrian persons without needing to apply to OFAC for a separate or specific license. Moreover, U.S. persons may donate humanitarian goods like food and medicine to people in Syria, as long as such donations are consistent with Commerce and OFAC regulations.
Finally, OFAC has also issued a general license to allow nongovernmental organizations (NGOs) to engage in not-for-profit activities in Syria in support of humanitarian projects, democracy-building, education, and non-commercial development projects directly benefitting the Syrian people. Copies of all OFAC general licenses issued for Syria can be found on OFAC's Syria Sanctions program page. For any activities that fall outside of these general licenses, specific authorization from OFAC would be required, unless the transactions fall within a small category that are exempt from regulation by statute.
As mentioned above, one of the goals of the U.S. sanctions on Syria is to reinforce the President’s call for Bashar al-Assad to step down and to disrupt the Assad regime’s ability to finance its campaign of violence against the Syrian people. OFAC can issue a specific license to authorize particular transactions that may otherwise be prohibited by the sanctions, as long as those transactions are in the foreign policy interests of the United States. For example, specific licenses may be issued on a case-by case basis to authorize charitable donations of funds that would otherwise be prohibited by the Syrian sanctions regime.
May I continue to send money to family or friends in Syria?
Yes. OFAC General License No. 6 authorizes U.S. depository institutions, including banks, and U.S.-registered money transmitters, to process non-commercial, personal remittances to or from Syria, or for or on behalf of an individual ordinarily resident in Syria, provided the funds transfer is not by, to, or through the Government of Syria or any other person designated or otherwise blocked by OFAC. Such transactions do not require further authorization from OFAC. If banks or other institutions have questions about processing remittances, they can contact the OFAC Compliance hotline.
No. General License No. 6 does not authorize any transactions involving individuals or entities designated under E.O. 13382, which targets proliferators of weapons of mass destruction and their supporters, including the Commercial Bank of Syria, the Syrian Lebanese Commercial Bank, and the SIIB. On August 10, 2011, under Executive Order 13382, the Department of the Treasury designated the Commercial Bank of Syria for its involvement in proliferation activities, and also designated its subsidiary, the Syrian-Lebanese Commercial Bank. On May 30, 2012, the Department of the Treasury also designated the SIIB. Therefore, the use of these financial institutions is not authorized by General License No. 6.
No. You may send U.S.-origin food or medicine to Syria without a specific license from OFAC. The Department of Commerce, Bureau of Industry and Security (“BIS”), which maintains jurisdiction over the export of most items to Syria, does not require a license for the export of U.S.-origin food and most medicine to Syria. For further guidance regarding the exportation of items to Syria, including a list of such items, please review the BIS Syria Web page, or contact BIS by phone at (202) 482-4252.
Can I give donations to NGOs to help the Syrian people?
Yes. U.S. persons can give a charitable donation to U.S. or third-country NGOs, but U.S. persons cannot send such a donation directly to Syria or a Syrian entity without a specific license in order to try to protect the donations from being misused. U.S. depository institutions, including banks, and U.S.-registered money transmitters, are allowed to process transfers of funds to or from Syria on behalf of U.S. NGOs and third-country NGOs in support of the not-for-profit activities described in OFAC General License No. 11.*
These not-for-profit activities include: (1) activities to support humanitarian projects to meet basic human needs in Syria, including drought relief, assistance to refugees, internally displaced persons, and conflict victims, food and medicine distribution, and the provision of health services; (2) activities to support democracy building in Syria, including rule of law, citizen participation, government accountability, and civil society development projects; (3) activities to support education in Syria, including combating illiteracy, increasing access to education, and assisting education reform projects; and (4) activities to support non-commercial development projects directly benefiting the Syrian people, including preventing infectious disease and promoting maternal/child health, sustainable agriculture, and clean water assistance.
General License No. 11 does not authorize transactions with the Government of Syria or other blocked persons, except for limited transactions with the Government of Syria that are necessary for the above-described not-for-profit activities, such as payment of taxes and other fees.
*For guidance on specific questions with respect to charitable donations, NGOs, and the scope of General License No. 11, please reach out to OFAC.
Can U.S. NGOs deliver humanitarian assistance directly to Syria?
Yes. U.S. NGOs may provide services to Syria in support of humanitarian projects in Syria as authorized by § 542.516 of the Syrian Sanctions Regulations. NGOs carrying out activities funded by the U.S. government, as described in § 542.522, or international organizations, as described in § 542.513, may also rely on those respective authorizations for their activities. Additionally, NGOs 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. However, other U.S. government authorities, including the Department of Commerce, Bureau of Industry and Security (BIS) export requirements, may apply to the delivery of humanitarian assistance to Syria. In particular, BIS maintains comprehensive restrictions on the export or reexport to Syria of items (commodities, software, and technology) subject to the Export Administration Regulations, 15 CFR parts 730-774 (EAR). These restrictions apply to all items subject to the EAR apart from food and medicine that are designated as EAR99. BIS licenses certain categories of items for export or reexport to Syria on a case-by-case basis. See EAR § 746.9. For further guidance, please review the BIS Syria Web page or contact BIS by phone at (202) 482-4252.
NGOs considering entering Syria to conduct assistance operations should be aware that areas of Syria are extremely unstable and dangerous, and should review the State Department’s Travel Warning for Syria http://travel.state.gov/content/passports/english/alertswarnings/syria-travel-warning.html.
U.S. persons should exercise caution not to engage in prohibited transactions with the Government of Syria or any individual or entity on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDN List) or any other sanctions list maintained by OFAC.
Updated: June 05, 2024
As a U.S. person, can I send financial donations directly to Syria in support of charitable activities under the Syria NGO General License at § 542.516 of the Syrian Sanctions Regulations (SySR)?
No. Without a specific license, U.S. persons are not permitted to transfer financial donations directly to Syria or to NGOs in Syria. If you wish to donate funds in support of humanitarian work in Syria, you may do so by giving funds to U.S. or third-country NGOs to support non-commercial activities in Syria.
If you still wish to send a charitable donation directly to Syria or to a Syrian NGO, you may apply to OFAC for specific authorization to transmit such funds. You should provide as much information as possible about how the funds would be transferred, the recipients, and the end use of the funds. Additionally, non-commercial, personal remittances can be sent to Syria under the Syria remittances general license at § 542.512 of the SySR.
Updated: June 05, 2024
What does Syria General License 20 authorize?
Syria General License (GL) 20 authorizes, subject to certain conditions, all transactions and activities prohibited by the Syrian Sanctions Regulations (SySR) that are ordinarily incident and necessary to the wind down of transactions involving, directly or indirectly, Emma Tel LLC or any entity in which Emma Tel LLC owns, directly or indirectly, a 50 percent or greater interest, through 12:01 a.m. eastern standard time, December 30, 2020. Persons unable to wind down transactions prohibited by the SySR involving, directly or indirectly, Emma Tel LLC, or any entity in which Emma Tel LLC owns, directly or indirectly, a 50 percent or greater interest, before 12:01 a.m. eastern standard time, December 30, 2020, are encouraged to seek guidance from OFAC.
For the duration of GL 20, non-U.S. persons may wind down transactions involving, directly or indirectly, Emma Tel LLC, or any entity in which Emma Tel LLC owns, directly or indirectly, a 50 percent or greater interest, without exposure to sanctions under the Caesar Syria Civilian Protection Act of 2019, provided that such wind down activity is consistent with GL 20. While GL 20 is in effect, wind down transactions involving non-U.S. persons may be processed through the U.S. financial system or involve U.S. persons, as long as the transactions comply with the terms and conditions in GL 20. Non-U.S. persons unable to wind down transactions involving, directly or indirectly, Emma Tel LLC or any entity in which Emma Tel LLC owns, directly or indirectly, a 50 percent or greater interest before 12:01 a.m. eastern standard time, December 30, 2020, are encouraged to seek guidance from OFAC.
The Central Bank of Syria (CBoS) is blocked as part of the Government of Syria, as defined in E.O. 13582 of August 17, 2011 and the Syrian Sanctions Regulations (SySR), 31 C.F.R. Part 542. On December 22, 2020, OFAC identified the CBoS on the Specially Designated Nationals and Blocked Persons List (SDN List), further underscoring its blocked status. This identification does not trigger new prohibitions on the CBoS. All property and interests in property of the CBoS remain blocked.
Among other things, the SySR generally prohibit U.S. persons, unless exempt or authorized, from engaging in any transaction or dealing in property and interests in property of certain blocked persons, including the CBoS. This also includes the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any person whose property and interests in property are blocked, again including the CBoS. The SySR also prohibit the export, reexport, sale, and supply of services to Syria (unless exempt or authorized), which would include services involving the CBoS in Syria.
Pursuant to the Caesar Syria Civilian Protection Act of 2019, non-U.S. persons who knowingly provide significant financial, material, or technological support to, or knowingly engage in a significant transaction with the Government of Syria, including the CBoS, or certain other persons sanctioned with respect to Syria, risk exposure to sanctions.
General and specific licenses under the SySR applicable to the CBoS continue to apply, including authorizations for the provision of humanitarian assistance and certain trade to Syria that may involve the CBoS. For more information regarding authorizations for humanitarian assistance and other trade with Syria by U.S. and non-U.S. persons, please see FAQ 867.
Can U.S. and non-U.S. persons provide humanitarian assistance to Syria following the identification of the Central Bank of Syria (CBoS) on the Specially Designated Nationals and Blocked Persons List (SDN List)?
Yes. The identification of the CBoS on the SDN List does not trigger new prohibitions; existing general and specific licenses under the Syrian Sanctions Regulations (SySR), 31 C.F.R. Part 542, continue to apply as they did previously. U.S. persons may continue engaging with the CBoS in connection with humanitarian assistance and certain other trade with Syria authorized by the SySR or exempt from regulation, including: § 542.510 (Exports or reexports to Syria of items licensed or otherwise authorized by the Department of Commerce authorized; exports or reexports of certain services authorized); § 542.513 (Official business of certain international organizations and entities); § 542.516 (Certain transactions in support of nongovernmental organizations’ activities); and § 542.525 (Exportation or reexportation of services to Syria related to the exportation or reexportation of certain non-U.S.-origin goods authorized). Of note, the export of U.S.-origin food and most medicines to Syria is not prohibited and does not require a Commerce or OFAC license (see 31 CFR § 542.510 and Syria FAQ 229), and U.S. persons can continue engaging with the CBoS in connection with these transactions. Furthermore, § 542.404 of the SySR authorizes transactions ordinarily incident and necessary to a licensed transaction, with certain exceptions.
In addition, OFAC may issue specific licenses to authorize certain transactions involving U.S. persons or the U.S. financial system that may otherwise be prohibited by OFAC sanctions, provided those transactions are in the foreign policy interests of the United States. OFAC has a longstanding licensing policy supporting the provision of humanitarian assistance.
With respect to non-U.S. persons, OFAC will not consider transactions to be “significant” for the purpose of a sanctions determination under the Caesar Syria Civilian Protection Act of 2019 (Caesar Act) if U.S. persons would not require a specific license from OFAC to participate in such a transaction. See 31 CFR § 542.414. Accordingly, non-U.S. persons would not risk exposure to sanctions under the Caesar Act for engaging in activity with the CBoS that is authorized for U.S. persons under a general license in the SySR, such as transactions involving the provision of humanitarian assistance or export of humanitarian goods to Syria. Further, the Caesar Act codifies, with some exceptions, the general license in § 542.516 of the SySR, as in effect the day before enactment of the Caesar Act, that authorizes certain services in support of nongovernmental organizations, and includes a humanitarian waiver.
OFAC remains committed to ensuring that humanitarian assistance can flow to the people of Syria. Treasury continues to support the critical work of governments, certain international organizations and entities, non-governmental organizations, and individuals delivering food, medicine, medical supplies, and humanitarian assistance to civilians in Syria. If individuals, companies, or financial institutions have questions about engaging in or processing transactions related to these authorizations, they can contact OFAC’s Compliance Division.
Updated: June 14, 2024
As described in FAQ 867, non-U.S. persons would not risk exposure to sanctions for engaging in humanitarian-related transactions or activity with Polymedics LLC and Letia Company that are exempt from regulation or authorized for U.S. persons by a general license in the Syrian Sanctions Regulations (SySR), 31 C.F.R. Part 542, such as transactions involving the provision of humanitarian assistance or export of humanitarian goods to Syria.
Additionally, the Caesar Syria Civilian Protection Act of 2019 (Caesar Act) codifies, with some exceptions, the general license in § 542.516 of the SySR, which authorizes certain services in support of nongovernmental organizations and includes a humanitarian waiver.
Do non-U.S. persons, including nongovernmental organizations (NGOs) and foreign financial institutions, risk exposure to U.S. secondary sanctions pursuant to the Caesar Syria Civilian Protection Act of 2019 (Caesar Act) for activities that would be authorized under the Syrian Sanctions Regulations (SySR)?
With respect to non-U.S. persons, OFAC will not consider transactions to be “significant” for the purpose of a sanctions determination under the Caesar Act if U.S. persons would not require a specific license from OFAC to participate in such a transaction. See 31 CFR § 542.414. Accordingly, non-U.S. persons, including NGOs and foreign financial institutions, would not risk exposure to sanctions under the Caesar Act for engaging in activity, or facilitating transactions and payments for such activity, that is authorized for U.S. persons under a general license (GL) issued pursuant to the SySR or exempt.
Section 7425 of the Caesar Act codifies, with some exceptions, the general license in § 542.516 of the SySR that authorizes certain services in support of NGOs. Additionally, Section 7432 of the Caesar Act includes a humanitarian waiver for activities not otherwise covered by GL § 542.516 of the SySR.
Furthermore, non-U.S. persons do not risk exposure to sanctions pursuant to the Caesar Act for engaging in or facilitating transactions and activities authorized pursuant to the General License at § 542.533, or transactions that are ordinarily incident and necessary to give effect to the activities authorized in § 542.533, or any other general license issued pursuant to the SySR.
Please note that this guidance with respect to non-U.S. persons does not apply to transactions and activities that may be subject to sanctions under other sanctions programs administered by OFAC (e.g., transactions with blocked persons designated under Executive Order (E.O.) 13224, as amended (OFAC’s counterterrorism authority) or E.O. 13894 (OFAC’s Syria-related authority)), unless exempt or otherwise permitted by OFAC.
Updated: June 14, 2024
May U.S. and non-U.S. persons, including nongovernmental organizations (NGOs) and foreign financial institutions, provide or facilitate certain humanitarian assistance to Syria without the risk of sanctions?
Yes. The export of U.S.-origin food and most medicines to Syria is not prohibited and does not require a Department of Commerce Bureau of Industry and Security (BIS) or OFAC license (see 31 CFR § 542.510, 15 CFR § 746.9, and Syria FAQ 229), and therefore non-U.S. persons would not risk exposure to sanctions under the Caesar Syria Civilian Protection Act of 2019 (Caesar Act) for engaging in such activity. See FAQ 884. For questions specific to transactions involving items subject to the Export Administration Regulations destined to Syria, please contact the BIS Foreign Policy Division at Foreign.Policy@bis.doc.gov. Additionally, U.S. persons providing services ordinarily incident to the export or reexport of certain non-U.S.-origin food and most medicines to Syria is not prohibited and does not require an OFAC specific license (see 31 CFR § 542.525), and therefore non-U.S. persons would not risk exposure to sanctions under the Caesar Act for engaging in such activity. For more information on the most relevant exemptions, exceptions, and authorizations for humanitarian assistance and trade under the Syria sanctions program, please see OFAC’s April 16, 2020 Fact Sheet: Provision of Humanitarian Assistance and Trade to Combat COVID-19 (this content is no longer available).
OFAC remains committed to ensuring that humanitarian assistance can flow to the people of Syria and maintains a favorable policy supporting the provision of humanitarian assistance. Treasury continues to support the critical work of governments, certain international organizations, NGOs, and individuals delivering food, medicine, medical supplies, and humanitarian assistance to civilians in Syria. In an effort to ensure assistance reaches those in need, we encourage individuals, companies, or financial institutions who have questions about engaging in or processing transactions related to these authorizations, to contact OFAC’s Sanctions Compliance and Evaluation Division at (800) 540-6322 or (202) 622-2490.
Are the United Nations and the U.S. government permitted to conduct stabilization and early recovery-related activities and transactions involving Syria? Does this apply to their contractors and grantees as well?
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
What does the general license (GL) at § 542.516 of the Syrian Sanctions Regulations (SySR), as amended on November 26, 2021, authorize with respect to nongovernmental organizations (NGOs)?
The GL at § 542.516 of the SySR continues to authorize, subject to certain limitations, NGOs to engage in certain transactions and activities that would otherwise be prohibited in support of the following not-for-profit activities in Syria:
The transactions and activities that NGOs are authorized to engage in include:
Early-recovery-related transactions and activities that fall within the categories of transactions and activities listed above are authorized. For transactions and activities not otherwise authorized or exempt from sanctions, OFAC considers license requests on a case-by-case basis.
Additionally, this GL authorizes U.S. financial institutions to process transfers of funds in support of the authorized transactions and activities outlined above. U.S. depository institutions, U.S. registered brokers or dealers in securities, and U.S. registered money transmitters 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. U.S. depository institutions, U.S. registered brokers or dealers in securities, and U.S. registered money transmitters are expected to conduct a level of due diligence commensurate with its overall risk profile and internal compliance policies and procedures with respect to a transaction involving Syria.
Separately, non-U.S. persons, including NGOs and foreign financial institutions, do not risk exposure to U.S. secondary sanctions pursuant to the Caesar Syria Civilian Protection Act of 2019 for engaging in or facilitating transactions and activities that are otherwise authorized or exempt for U.S. persons under the SySR. Please see 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.
Date Updated: August 8, 2023
What early-recovery-related transactions and activities are nongovernmental organizations (NGOs) authorized to engage in pursuant to the general license (GL) at § 542.516 of the Syrian Sanctions Regulations (SySR), as amended on June 5, 2024?
The GL at § 542.516 of the SySR authorizes NGOs to engage in activities in support of certain non-commercial activities in Syria, including: humanitarian projects to meet basic human needs; democracy-building; education; non-commercial development projects directly benefitting the Syrian people; the preservation and protection of cultural heritage sites; environmental and natural resource protection; and disarmament, demobilization, and reintegration (DDR) programs and peacebuilding, conflict prevention, and conflict resolution programs. This includes early-recovery-related transactions and activities by NGOs in support of transactions and activities that fall within the categories listed above, including:
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.
For transactions and activities not otherwise authorized or exempt from sanctions, OFAC considers license requests on a case-by-case basis. Individuals, NGOs, companies, or financial institutions with questions about engaging in or processing transactions or activities related to this authorization can contact OFAC’s Compliance Division.
Updated: June 05, 2024
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.
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 of 2019 from the scope of the authorization. Additional information on activities authorized pursuant to Syria GL 22 can be found in FAQ 1043.
What activities are authorized pursuant to Syria General License (GL) 22?
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 waste management; health services; education; manufacturing; and trade. This includes activities in the areas of northeast and northwest Syria identified in the Annex in Syria GL 22, in support of transactions and activities that fall within the categories listed above, including:
Additionally, Syria GL 22 authorizes U.S. financial institutions to process transfers of funds in support of the authorized transactions and activities outlined above.
Separately, non-U.S. persons, including foreign financial institutions, do not risk exposure to U.S. secondary sanctions pursuant to the Caesar Syria Civilian Protection Act of 2019 for engaging in or facilitating transactions and activities that are otherwise authorized or exempt for U.S. persons under the SySR. Please see FAQ 884 for additional information.
Please note that this guidance does not apply to transactions and activities that may be subject to prohibitions 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. Any persons seeking to operate in non-regime held areas of northeast and northwest Syria must ensure their in-country activities do not involve prohibited transactions and activities or blocked persons, such as the Government of Syria or designated terrorist organizations.
For transactions and activities not otherwise authorized or exempt from sanctions, OFAC will consider license requests on a case-by-case basis. Individuals, companies, or financial institutions with questions about engaging in or processing transactions related to this authorization can contact the OFAC Compliance Hotline.
Additionally, U.S. and non-U.S. persons may need to obtain a license from the Department of Commerce’s Bureau of Industry and Security (BIS) for the export or reexport or certain items subject to Export Administration Regulations (EAR). For further guidance regarding the exportation or reexportation of items to Syria, please contact BIS at (202) 482-4252.
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 financial institutions may reasonably rely upon the information available to them in the ordinary course of business with regard to compliance with Syria GL 22, provided that the financial institution does not know or have reason to know that the funds transfer is not in compliance with the provisions of the GL.
In addition, foreign financial institutions do not risk exposure to U.S. secondary sanctions pursuant to the Caesar Syria Civilian Protection Act of 2019 for engaging in or facilitating transactions and activities that are otherwise authorized or exempt for U.S. persons under the Syrian Sanctions Regulations. Please see FAQ 884 for additional information.
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, 31 C.F.R. part 542, including the Government of Syria, or persons that may be subject to sanctions under other sanctions programs administered by OFAC (e.g., transactions with blocked persons designated under Executive Order (E.O.) 13224, as amended (OFAC’s counterterrorism authority), or E.O. 13894 (OFAC’s Syria-related authority)), unless exempt or otherwise authorized by OFAC.
Persons conducting activities in certain non-regime held areas in northeast and northwest Syria pursuant to Syria GL 22 can use OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List) Search Tool to identify organizations and individuals explicitly included on the SDN List, as well as other individuals or entities explicitly subject to U.S. sanctions. For more information on using OFAC’s SDN List Search Tool and assessing OFAC Name Matches, please see OFAC FAQs 5, 82, 246-253, 287, 369, 467, and 892.
In addition, according to OFAC’s 50 Percent Rule entities are considered blocked if they are owned 50 percent or more, directly or indirectly, individually or in the aggregate, by one or more blocked persons.
OFAC would encourage any persons operating in certain non-regime held areas of northeast and northwest Syria pursuant to Syria GL 22 to use all information at their disposal when assessing their risk for sanctions exposure. Supplementing internal due diligence information with an array of open-source material can be an effective compliance practice to aid in identifying risky counterparties involved in any in-country activity. For more information on OFAC due diligence expectations and compliance programs, please see FAQs 25, 27-31 and A Framework for OFAC Compliance Commitments.
What changes did OFAC make in the June 5, 2024 regulatory amendments to the Syrian Sanctions Regulations, 31 CFR part 542 (SySR)?
On June 5, 2024, OFAC, in consultation with the Department of State, amended the SySR to, among other things, incorporate certain sanctions statutes, including the Caesar Syria Civilian Protection Act of 2019, which are designed to deny the Assad Regime the resources it needs to support its longstanding campaign of repression against the Syrian people. The amendments also incorporate a web General License (GL) and modify certain existing GLs to facilitate the continued provision of legitimate humanitarian assistance and internet-based communications services to civilians in Syria and clarify the applicability of the SySR to persons sanctioned under certain sanctions authorities. These changes include:
OFAC incorporated into the SySR the Caesar Syria Civilian Protection Act of 2019, the Syria Human Rights Accountability Act of 2012, and the Iran Threat Reduction and Syria Human Rights Act of 2012, as well as relevant provisions of the Countering America’s Adversaries Through Sanctions Act and Executive Order (E.O.) 13608.
OFAC incorporated into the SySR, at new § 542.533, web GL 22, which authorizes activities in certain economic sectors in non-regime held areas of Northeast and Northwest Syria.
OFAC amended the GL related to the activities of nongovernmental organizations (NGO) at § 542.516. These changes clarify which types of persons are covered by the NGO GL; add new authorized activities; and clarify that U.S. financial institutions may rely on statements of the originator of a funds, provided that the financial institution does not know or have reason to know that the funds transfer is not in compliance with the NGO GL.
OFAC amended the GL related to the activities of international organizations (IO) at § 542.513. These changes add new IOs whose official business is authorized by the GL to include 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.
OFAC amended the GL related to internet-based communications at § 542.511. These changes update the list of examples of communications technologies that are incident to, or enable services incident to, communications over the internet; authorize the provision of services incident to the export or reexport of certain communications software or hardware not subject to the Export Administration Regulations (“EAR”), 15 C.F.R. parts 730-774, that is incident to, or enables services incident to, communications over the internet, subject to certain conditions; and authorize the exportation and re-exportation to Syria of non-commercial-grade internet connectivity services
For more information, see FAQs 205, 206, 231, 232, 934, and 938.