OFAC licence permits certain transactions in Northeast and Northwest Syria

The US Treasury’s Office of Foreign Assets Control (‘OFAC’) has issued a new general licence (GL22), which permits US persons to undertake transactions ‘ordinarily incident and necessary to’ a broad swathe of activities, including agriculture, ITC, construction, finance, waste collection, clean energy, health services, and manufacturing and trade, in specific areas in the northeast and northwest of the country that are not under the administration of the government of Bashar Al-Assad.

In FAQs, it is noted that ‘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.’

OFAC says that it encourages persons who might be operating in the relevant territories to ‘use all information at their disposal when assessing their risk for sanctions exposure,’ adding, ‘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.’

FAQs also emphasise that non-US persons do not risk sanctions exposure for activities that are permitted to US persons under a general licence.

https://home.treasury.gov/policy-issues/financial-sanctions/recent-actions/20220512