OFAC’s Syria sanctions are designed to deter Bashar al-Assad, his cronies, foreign enablers, and the Government of Syria from accessing the international financial system and global supply chain. In addition, there are many illicit actors that operate in Syria, such as those related to Specially Designated Global Terrorists, Iran, or Russia, which may trigger additional sanctions prohibitions. OFAC remains committed to ensuring that these sanctions do not limit the ability of civilians located in Syria to receive humanitarian support from the international community. Such support may include providing items to the civilians of Syria, to include testing kits, respiratory devices, personal protective equipment, and medicine used in the prevention, diagnosis, treatment, and recovery from COVID-19. The United States government aims to work closely with the international organizations and humanitarian assistance community to address any obstacles.
General Licenses (GLs) and Specific Licensing: The following are GLs within the Syrian Sanctions Regulations (SySR) issued by OFAC related to humanitarian assistance and trade with Syria. Similarly, the exemptions below are also captured in title LXXI of the National Defense Authorization Act for Fiscal Year 2020, titled the “Caesar Syria Civilian Protection Act of 2019,” which codifies the GL in § 542.516 of the SySR (discussed below) that authorizes certain services in support of non-governmental organizations (NGO), and includes a humanitarian waiver.
• § 542.510 of the SySR authorizes certain exports or reexports to Syria of items licensed or otherwise authorized by the Department of Commerce (Commerce) and certain related services. This GL also authorizes certain services that are ordinarily incident to the exportation or reexportation of items to Syria and certain other services to install, repair, or replace such items, provided the export of such items is licensed or otherwise authorized by Commerce. Additionally, export of U.S. origin food and most medicines to Syria is not prohibited and does not require a Commerce or OFAC license (see Syria FAQ 229).
• § 542.512 of the SySR generally authorizes, subject to certain limitations, non- commercial personal remittances to or from Syria. OFAC also authorizes U.S. depository institutions, including banks and U.S.-registered money transmitters, to process noncommercial, 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 person designated or otherwise blocked by OFAC.
• § 542.513 of the SySR authorizes activities of certain international organizations.
Subject to certain narrow limitations, the GL authorizes transactions and activities that are for the conduct of the official business of the United Nations, including its specialized agencies, programmes, funds, and related organizations by employees, contractors, or grantees of those organizations.
• § 542.516 of the SySR authorizes, subject to certain limitations, NGOs to provide certain services in support of, and certain U.S. financial institutions to process transfers of funds in support of, the following not-for-profit activities in Syria:
o Humanitarian projects that meet basic human needs; o Democracy-building;
o Projects supporting education;
o Non-commercial development projects directly benefitting the Syrian people; and
o Activities to support the preservation and protection of cultural heritage sites.
• § 542.525 of the SySR authorizes the exportation, reexportation, sale, or supply, directly
or indirectly, from the United States or by a U.S. person, wherever located, to Syria, including the Government of Syria, of services that are ordinarily incident to the exportation or reexportation to Syria, including to the Government of Syria, of non-U.S.- origin food, medicine, and medical devices that would be designated as EAR99 under the Export Administration Regulations (EAR) if it were subject to the EAR.
• § 542.532 of the SySR authorizes the provision on nonscheduled emergency medical services.
• Specific Licensing: For transactions not otherwise authorized by OFAC general licenses, OFAC considers specific license requests on a case-by-case basis and prioritizes license applications, compliance questions, and other requests related to humanitarian support for the Syrian people.