U.S. Treasury Expands Syria Nongovernmental Organizations General License
November 24, 2021
Amends Syria Sanctions Regulations and Issues Two New FAQs
WASHINGTON — Today, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) amended the Syrian Sanctions Regulations (SySR) to expand the authorizations for nongovernmental organizations (NGO) to engage in certain transactions and activities. This action — which builds upon the U.S. government’s longstanding humanitarian exemptions, exceptions, and authorizations in the Syria sanctions program — helps ensure the continued provision of humanitarian assistance, including certain early-recovery activities, that benefit the Syrian people. Treasury’s recent sanctions review highlighted the need for continued review of existing authorities to facilitate legitimate humanitarian activity while continuing to deny support to malicious actors.
As part of this commitment, OFAC amended the NGO general license (GL) at § 542.516of the SySR. The amended GL authorizes NGOs to engage in the following additional transactions and activities in support of certain not-for-profit activities in Syria: new investment in Syria; the purchase of refined petroleum products of Syrian origin for use in Syria; and certain transactions with elements of the Government of Syria. These new transactions and activities are authorized only in support of the not-for-profit activities already authorized under the GL, including humanitarian projects that meet basic human needs, democracy-building, projects supporting education, non-commercial development projects directly benefitting the Syrian people, and activities to support the preservation and protection of cultural heritage sites.
Additionally, the NGO GL authorizes U.S. financial institutions to process transfers of funds in support of the authorized transactions and activities outlined above. This amendment will take effect on November 26, 2021. For more information on what the NGO GL at § 542.516 authorizes, as well as guidance for non-U.S. persons engaging in or facilitating transactions and activities authorized for U.S. persons under the amended GL, please refer to FAQ 937. Additional information on early recovery transactions and activities authorized pursuant to the amended NGO GL can be found in FAQ 938.
“The U.S. government prioritizes expanding humanitarian access throughout Syria to alleviate the suffering of the Syrian people, who continue to face armed conflict, food insecurity, and the COVID-19 pandemic. The U.S. remains committed to ensuring that humanitarian assistance from the international community, including early-recovery-related humanitarian activities, reaches Syrian civilians,” said OFAC Director Andrea M. Gacki. “The United States continues to focus on deterring the malign activities of Bashar al-Assad, his regime, cronies, and foreign enablers, as well as terrorist groups, including by limiting their ability to access the international financial system and global supply chains.”
OFAC encourages those interested in providing humanitarian assistance to Syria to avail themselves of the longstanding exemptions and authorizations pertaining to humanitarian assistance, as further described in FAQs 884, 885, and 934. For a summary of the most relevant exemptions, exceptions, and authorizations for humanitarian assistance under the Syria sanctions programs, please refer to the Office of Foreign Assets Control’s COVID-19-related Fact Sheet. Should individuals, governments, or entities have sanctions-related questions about the provision of humanitarian assistance to Syria, or believe additional authorizations are needed, OFAC stands ready to provide guidance and respond to applications for specific licenses.
For transactions not otherwise authorized or exempt from sanctions, OFAC considers license requests on a case-by-case basis and prioritizes applications, compliance questions, and other requests related to humanitarian support. If you have additional questions regarding the scope of any sanctions programs’ requirements, or the applicability or scope of any humanitarian-related authorizations, please contact OFAC’s Sanctions Compliance and Evaluation Division at (800) 540-6322 or (202) 622-2490, or by email at OFAC_Feedback@treasury.gov.
Note: Notice that Wednesday’s OFAC release included an updated Venezuela General License, not a Syria one. That’s because the exemptions of the “general license” are housed in the updated Syrian Sanctions Regulations, not in a standalone General License document. It’s a good thing to note: from time to time, GLs may get pulled into the regulatory text, and disappear as separate documents. To fully understand the available exemptions, you need to bone up on both.