New OFAC Syrian Executive Order – What it really means for business (Part I)

OFAC has added new entities to the Specially Designated Nationals (SDN) list.  The targeted Syrian sanctions included blocking the Government owed Commercial Bank of Syria and its subsidiary the Syrian Lebanese Commercial Bank.

The White House issued an Executive Order blocking property of the Syrian Government and prohibiting most transactions with Syria.   The Order prohibits:

1.      new investment in Syria by U.S. persons

2.      the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of any services to Syria

3.      the importation of petroleum and petroleum products of Syrian origin and any transaction or dealing by a U.S. person in or related to Syrian petroleum or petroleum products

4.      a U.S. person’s approval, financing, facilitation, or guarantee of a foreign person’s transaction if that transaction would be prohibited if done by the U.S. person or within the U.S.

5.      donations to or for the benefit of any person with blocked property or interests

Simultaneously, OFAC issued six General Licenses allowing specific Syrian transactions.  Over the next two months, another eight Licenses were released, making 14 General Licenses in total.