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Sanctions Targeting Syria

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As anticipated in its press release, the EU yesterday published in the Official Journal the first legal instruments underpinning its decision to progressively suspend its sanctions against Syria: Decision 2025/406/CFSP, Council Regulation 2025/407 and Council Implementing Regulation 2025/408. The measures include the suspension of a significant number of sanctions which have been in place for over a decade, most recently contained within Council Regulation 36/2012, as summarised below. Companies considering business in Syria previously restricted…

On June 5, 2024, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended the Syrian Sanctions Regulations (“SSR”), 31 C.F.R. Part 542 and issued and amended frequently asked questions (“FAQs”) related to the SSR. According to a new OFAC FAQ, these changes are aimed, in part, at facilitating humanitarian assistance and internet-based communication services to Syrian civilians. The SSR has been revised as follows: OFAC also issued one new SSR FAQ…

On February 17, the Bureau of Industry and Security (“BIS”) in the US Commerce Department announced that it is expediting the processing of export license applications for items needed to aid survivors of the earthquakes in Türkiye and Syria through NGOs.  While most items subject to the Export Administration Regulations (“EAR”) do not require licenses for export to Türkiye, Syria is subject to comprehensive US export controls and, as such, items subject to the EAR…

On February 9, 2023, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Syria General License 23, “Authorizing Transactions Related to Earthquake Relief Efforts in Syria.” General License 23 authorizes transactions related to earthquake relief efforts in Syria that would otherwise be prohibited by the Syrian Sanctions Regulations (“SySR”) through 12:01 p.m. eastern daylight time, August 8, 2023. General License 23 does not authorize importation of petroleum or petroleum products of…