The trend of general licenses being issued by the United States Department of the Treasury Office of Foreign Assets Control (OFAC) in relation to sanctions against Syria was continued today, when OFAC issued Syria General Licenses 13 and 14, which deal with payments for overflights and emergency landings and with transactions related to telecommunications, respectively.

Syria General License 13 merely states that payments to Syria for charges rendered by the Syrian Government for overflights and emergency landings are permitted, so long as no blocked party has an interest in that transaction.

Syria General License 14 states that all transactions with respect to the receipt and transmission of telecommunications is authorized so long as it does not entail the debiting of any Government of Syria accounts on the books of a U.S. depository institution, and does not involve any persons blocked pursuant to sanctions. Syria General License 14 does not, however, permit transactions with the Govemment of Syria or to a person in Syria of telecommunications equipment or technology or telecommunications transmission facilities (such as satellite or terrestrial network connectivity) to Syria.

I have been receiving a lot of questions about general licenses and specific licenses the past few weeks. It seems that some people are getting the two confused. A general license is an open authorization for U.S. persons to engage in activity that would otherwise be prohibited by sanctions. It is not an exemption, however, because a general license can be revoked at any time by OFAC. A specific license on the other hand is an authorization that is requested and given on a case by case basis for the party actually applying for such authorization. As such, the general licenses above do not require any additional application or submission to OFAC for their use, although, in certain scenarios you may want to contact OFAC’s compliance division to ensure that activities you propose to take under a particular general license are indeed authorized by that general license.

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.