The bulk of OFAC’s June 17th designations bore the program tag [SYRIA-E.O.13894]. This Executive Order is the only one issued under the “Syria-related” sanctions program. This Executive Order allows the designation of people belonging to the Turkish government, any subdivision of it, or anyone determined to be:
(A) to be responsible for or complicit in, or to have directly or indirectly engaged in, or attempted to engage in, any of the following in or in relation to Syria:
(1) actions or policies that further threaten the peace, security, stability, or territorial integrity of Syria; or
(2) the commission of serious human rights abuse;
Clearly, the designations on the 17th were for these reasons, as they also occurred on the same day a number of designations were made under the new Caesar Syria Civilian Protection Act authorities.
So, why are there two Syria sanctions program? Why not just roll the two together, especially since the stand-off with Syria over its incursion into Northern Syria (where they threatened the Kurdish population) is over with?