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Sanctions Targeting Syria

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On November 26, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) published a final rule amending the Syrian Sanctions Regulations (“Final Rule”). The Final Rule expands the existing general license at § 542.516 (the “General License”) to authorize nongovernmental organizations (“NGOs”) to engage in certain assistance-related investment activities in support of not-for-profit activities in Syria. The General License authorizes NGOs to export/reexport services to Syria in support of not-for-profit activities in Syria, i.e., humanitarian projects…

The UK has designated six individuals as subject to financial sanctions and asset freeze measures under the Syria (Sanctions) (EU Exit) Regulations 2019 (S.I. 2019/792). The designated persons are: Muhammad Bara AL-QATIRJI,Faisal AL-MIQDAD,Luna AL-SHIBL,Malik ALIAA,Yasser Hussein IBRAHIM,Zaid SALAH. Separately, two entries under the UK’s Iran (Nuclear) financial sanctions regime have been amended. These entries have been added to the UK sanctions list and to the Office of Financial Sanctions Implementation’s Consolidated list of financial sanctions…

On June 3, 2020, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued new Syria-Related Sanctions Regulations (the “Regulations”), effective June 5, 2020, to implement Executive Order 13894 (“EO 13894”) issued by the President on October 14, 2019 in light of Turkey’s military actions in Syria. The Regulations are a codification of EO 13894 and do not represent new sanctions against Syria. They are also separate from US comprehensive sanctions targeting Syria under…

On May 14, 2020, the US Department of State, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), and the US Coast Guard issued guidance to the private sector aimed at preventing deceptive shipping practices used in sanctions evasion, smuggling, facilitation of terrorism, and other criminal activity (the “Advisory”).  The Advisory focuses on tactics recently used by malign actors to evade sanctions and sets out a non-exhaustive list of best practices companies…