Today the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License 4A. This general license replaces and supersedes the previously issued Syria General License 4. General License 4A authorizes the export to Syria of any items authorized and licensed for export to Syria by the United States Department of the Commerce.

This general license extends not only to the export, but also to the reexport of items, both to Syria and to the Government of Syria. Included among these parties eligible to receive exports from the U.S. are those parties blocked pursuant to the Syria sanctions programs. Such parties are on the OFAC Specially Designated Nationals List (SDN) and are identified as [SYRIA].

In addition, the exportation and reexportation, directly or indirectly, to Syria or the parties described in the paragraph above of services that are ordinarily incident to the exportation or reexportation of items to Syria, or of
services to install, repair, or replace such items, are also authorized, provided that the items to be exported are licensed or otherwise authorized by the Department of Commerce.

It should be understood that despite allowing for dealings with blocked persons, this general license does not allow the debiting of any blocked account. Moreover, it does not authorize exportation or reexportation of any item not subject to the Export Administration Regulations.

This move was a little bit surprising in little of all that is currently going in Syria. However, it shows the strong connection between OFAC and the Department of Commerce, in particular the Bureau of Industry and Security (“BIS”) Finally, a word of caution to those who saw this general license and thought about immediately engaging in trade with Syria; the exports still need to be authorized under the Department of Commerce’s regulations, which in some cases can be as tricky as, if not trickier than, OFAC’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.