Yesterday, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued further guidance concerning a few general licenses issued under the Syrian sanctions program. In its clarifications, OFAC made it clear that travel and travel related transactions are exempted from the Syrian sanctions, that the export of food and medicine is generally authorized and no separate specific license is needed if the goods are classified as EAR99 by the Department of Commerce’s Bureau of Industry and Security, that personal remittances can continue to flow between Syria and the United States so long as no blocked parties are involved, and that NGOs sending funds to Syria under General License 11 must use U.S. depository institutions, U.S. registered brokers, and U.S. register money transmitting businesses.

Travel related transactions to Syria by U.S. persons are not authorized by general license, but rather by the travel exemption contained in the International Emergency Economic Powers Act (IEEPA). That exemption not only also for travel to sanctioned countries, but also allows for travel related transactions such as transactions necessary for living expenses and for goods and services for personal use. Also of interest to some may be the export of food and medicine to Syria of EAR99 articles without separate specific OFAC licensing. While the general license for food is also in place for Iran and Sudan, it is the general license authorization for medicine that may be surprising to some.

U.S. unilateral sanctions targeting Syria are not as powerful as one might imagine. The level of trade and transactions prior to the imposition of the latest rounds of sanctions targeting Syria was limited and remains limited in comparison to a country such as Iran. This may be the reason why OFAC and the U.S. government is being fairly liberal in their licensing policy in regards to Syria.