ARTICLE
2 December 2021

OFAC Amends Syria Sanctions Regulations To Authorize Certain NGO Activities

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Cadwalader, Wickersham & Taft LLP

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OFAC adopted a final rule amending a General License ("GL") in the Syrian Sanction Regulations.
Worldwide International Law
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OFAC adopted a final  rule amending a General License ("GL") in the Syrian Sanction Regulations ("CFR Part 542"). The final rule expands the existing license to continue allowing NGOs to engage in certain assistance-related activities in support of humanitarian activities (at Section 542.516), including:

  • healthcare and health-related services;
  • educational support and training services;
  • agricultural-related services; and
  • activities related to shelter and settlement assistance, and clean water assistance.

Consistent with the Caesar Syria Civilian Protection Act of 2019, the final rule also amends the GL "to reflect that it does not apply to any foreign person that has been designated as a foreign terrorist organization" pursuant to Section 219 ("Designation of foreign terrorist organization") of the Immigration and Nationality Act. OFAC issued two related FAQs (see FAQs 937 and 938).

Primary Sources

  1. Treasury Press Release: Publication of Amended Syria Sanctions Regulations and Related Frequently Asked Questions; Issuance of Venezuela-related General License 8I
  2. OFAC Final Rule: Syrian Sanctions Regulations
  3. OFAC FAQ: Syria Sanctions - 937
  4. OFAC FAQ: Syria Sanctions - 938

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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