humanitarian-aid 02 December 2021

OFAC rule allows NGOs more significant dealings in Syria

The US Treasury’s Office of Foreign Assets Control (‘OFAC’) has published a final rule which expands an existing general licence ‘to engage in certain assistance-related investment activities in support of certain not-for-profit activities in Syria, including

  1. new investment in Syria that would be prohibited by § 542.206 [of the Syria Sanctions Regulations];
  2. additional dealings with a limited subset of the Government of Syria as defined in § 542.305(a) that would be prohibited by § 542.201(a)(1); and
  3. the purchase of refined petroleum products of Syrian origin that would be prohibited by § 542.209.’

A recent paper published by Germany’s Impact group for Civil Society Research and Development found that ‘NGOs and INGOs working on and / or operating in Syria have faced ever-increasing difficulties and some have had to cancel projects because they could not keep up with the paperwork required by donors. Unfortunately, despite various global initiatives and conference that have taken place in recent years between various actors (NGOs and INGOs, states officials, and banking employees) to improve and facilitate the financial operations and transfers of NGOs working on or in Syria, there has been no significant progress made to date; frequently quite the opposite.’

https://impact-csrd.org/reports/Invisible_Sanctions_IMPACT_EN.pdf

https://home.treasury.gov/system/files/126/frn_syria_reg_ngo.pdf