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Last Friday, the United States Department of the Treasury Office of Foreign Assets Control (OFAC) issued another series of general licenses authorizing certain transactions which would otherwise be prohibited under the Syria sanctions program. Those general licenses include authorizations for the following activities:

1. Wind down transactions: This general license allows for all transactions incidental to winding down contracts or business in Syria. For example, this general license authorizes divestiture or transfer to a foreign person of a U.S. person’s share of ownership, including an equity interest, in pre-August 18, 2011 investments located in Syria and to the winding down of a contractual or other commitments that were in effect prior to August 18, 2011 related to the exportation of services to Syria. It should be noted that this authorization is only granted through November 25, 2011 and contains reporting requirements.

2. Official activities of certain international organizations: This general license authorizes all activities and transactions related to the conduct of the official business of the United Nations, its Specialized Agencies, Programmes, and Funds, by employees, contractors, or grantees.

3. Transactions Related to U.S. persons residing in Syria: This general license authorizes U.S. persons residing in Syria to engage in transactions related to their personal maintenance and living expenses. Examples of such transactions include payment of housing expenses, acquisition of goods or services for personal use, payment of taxes or fees to the Government of Syria, and purchase or receipt of permits, licenses, or public utility services from the Government of Syria. This general license does not authorize transactions related to operating a business in Syria, nor does it authorize transactions with blocked persons.

4. Operation of Accounts: This general license allows for the operation of a U.S. account for those residing in Syria for transactions which are personal in nature and do not benefit Syria or those normally residing in Syria.

The question of accounts is one that surely needs to be addressed and I am glad to see that OFAC addressed it. Our office received a number of calls over the last 10 days or so from those Syrians (primarily graduate students) who have had their U.S. accounts blocked as a result of the newly imposed services to Syria ban. Hopefully these new general licenses, in particular General Licenses 9 and 10, will help to address those issues for Syrians currently residing in the U.S.

The author of this blog is Erich Ferrari, an attorney specializing in OFAC matters. If you have any questions please contact him at 202-280-6370 or ferrari@ferrari-legal.com.

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