On the heels of the issuance of a new round of sanctions against Syria, the United States Department of the Treasury Office of Foreign Assets Control(OFAC) has promulgated a series of general licenses to authorize certain transactions with the Syria that are now otherwise prohibited due to the new sanctions.

The Syria general licenses promulgated yesterday by OFAC number six (6) in total and cover transactions involving diplomatic services, legal services, certain bank service charges, exportation of items subject to the Export Administration Regulations and related services, internet based services, and personal remittances. A summary of each general license is found below:

1. Diplomatic services: This general license allows for U.S. persons to provide services to both Syrian diplomatic missions, as well as, the employees of Syrian diplomatic missions. Those services provided to diplomatic missions must be for the official business of the mission or for the personal use of the missions’ employees and cannot involve a transaction for the purchase, sale, or financing of real property.

2. Legal services: This general license allows for U.S. persons to provide certain legal services to Syria including counseling on compliance with U.S. laws, representation of parties in U.S. legal or administrative proceedings, representation before U.S. governmental bodies in matters related to the imposition and administration of sanctions, and any services for which prevailing U.S. law allows for access to legal counsel at the public expense. All receipts of payment and/or reimbursement for these services must still be specifically licensed by OFAC.

3. Bank service charges: This general license allows for U.S. financial institutions to debit accounts blocked under the Syria sanctions for normal services charges owed to the financial institution by the owner of the blocked account.

4. Services incidental to authorized exportation: This general license allows for the provision of services incidental to the authorized export of items to Syria. The items in question are defined as commodities, software, and technology licensed by the U.S. Department of the Commerce.

5. Internet based services: This general license allows for the provision of services incidental to the exchange of personal communications over the internet. This general license does not extend to provision of such services to blocked parties or the Government of Syria, the provision of connectivity or telecommunications transmissions services, the provision or certain web-hosting or domain registration services, or the export of items to Syria.

6. Personal remittances: This general licenses allows U.S. depository institutions and money transmitters to receive and send non-commercial personal remittances from or to Syria on behalf on an individual normally resident in Syria. Such transactions do not include charitable donations or funds used to support the operations of a business entity. This general license does not include personal remittances to blocked parties or the Government of Syria.

As I mentioned in yesterday’s posting, there will be a lot of work to do in relation to this new Syria country based sanctions program. However, these general licenses will reduce the amount of work for compliance officers and attorneys seeking to keep their companies or clients on the right side of the law regarding these new sanctions. Not that I question OFAC’s altruistic nature, however, these general licenses should also greatly reduce the number of questions OFAC will get over the next few weeks about these new Syria sanctions.

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.