This week the United States Department of the Treasury Office of Foreign Assets Control (OFAC) issued Syria General Licenses 11 and 12, further clarifying the activities which are and are not prohibited under the U.S. economic sanctions imposed against Syria earlier this year. These general licenses address issues concerning transactions for services in support of non-governmental organizations and transactions for the operating expenses of third-country diplomatic and consular services, respectively.

Syria General License 11 authorizes nongovernmental organizations to export or re-export certain services to Syria that would otherwise be prohibited by Executive Order 13582. The list of services authorized under this general license includes: services in support of activities to meet basic human needs in Syria, activities to assist democracy building in Syria, activities to support education in Syria, and activities to support non-commercial development projects directly benefiting the Syrian people.

As a result of these new authorizations U.S. financial institutions are authorized to process transfers to and from Syria that are related to any of the aforementioned activities. Moreover, nongovernmental organizations are authorized to engage in such transactions with the Government of Syria, however, the contribution of financial donations to the Government of Syria or any other party blocked pursuant to the U.S. sanctions imposed against Syria are not permitted without specific license authorization from OFAC.

As stated above, Syria General License 12 authorizes transactions for the operating expenses of third-country diplomatic and consular services. This authorization does not cover, however, transactions with the Government of Syria or any party blocked pursuant to the U.S. sanctions imposed against Syria.

These new general licenses are part of a trend which OFAC has engaged in recently related to the issuance of general licenses to address concerns and questions arising from a blitz of executive orders this year which targeted Libya, Syria and Transnational Criminal Organizations for sanctions. Considering that it typically takes OFAC over a year to promulgate regulations to correspond with an executive order imposing a new sanctions program, the use of these general licenses is a quick and effective way to cut back on the amount of questions and specific license applications OFAC would otherwise be receiving.

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.