Syria Sanctions Regime

The Syria Sanctions Regime was initiated by the Office of Foreign Assets Control (“OFAC”) in 2004, starting with Executive Order No. 1338. This was due to the Government of Syria’s support for terrorism and Weapons of Mass Destruction Program.  The Executive Orders that followed further intensified the sanction regime in place. This includes Executive Order Nos. 13399 and 13460; 135272, 13573, 13582, 13606, and 13608. The Syria Sanctions Regime is one of the

Syria is the target of broad country-based sanction regime like that of Iran and North Korea. The Syrian sanctions instruct U.S. persons and entities to block property of the Government of Syria; anybody on the Specially Designated Nationals and Blocked Persons List (SDN List) in Syria; prohibit any transactions with anybody under Executive Order No. 13608, and prohibit Syrian transactions with respect to Syria under Executive Order No. 13582.

Executive Order 13582

One of the executive orders from the Syria Sanctions Regime, Executive Order 13582, prohibits any new investments in Syria by a U.S. person, wherever located; the direct or indirect exportation/re-exportation sale or supply of any services to Syria from the U.S. or by a U.S. person, wherever located; the importation into the U.S. of petroleum or petroleum products with Syrian origin; any transactions by a U.S. person, wherever located, related to petroleum or petroleum products of Syrian origin, and any approval, financing, facilitation or guarantee by a U.S. person, wherever located, of a transaction by a foreign person where the transaction by that foreign person would be prohibited if performed by a U.S. person or within the United Sates.

What Transactions Are Exempt?

Certain types of transactions may be exempt from the Syria Sanctions Regulations (the SSR) and the Executive Orders. General Licenses include the exportation or re-exportation of goods licensed by the Department of Commerce; non-commercial personal remittances to or from Syria; transactions related to U.S. persons residing in Syria; the export and re-export of services in support of humanitarian and other not-for-profit activities in Syria by U.S. and third country non-governmental organizations; and certain transactions related to intellectual property protection.

Syria Sanctions Regulation also includes permissibility of case-by-case Specific Licenses submitted to OFAC’s Licensing Division, like all other sanction regimes in place, and penalties for violations of the Syria Sanctions Regime and related executive orders are civil monetary penalties of up to $250,000, or twice the amount of the underlying transactions. Criminal fines may be up to $1 million, imprisonment up to 20 years, or both.