Just before the holidays, President Biden signed two bills passed in the final days of the last Congress that contain a number of provisions with implications for sanctions, export controls, and supply chain restrictions: On December 23, 2022, President Biden signed into law the National Defense Authorization Act (“NDAA”) for Fiscal Year 2023 (P.L. 117-263). The measure includes a number of provisions relating to US export controls, sanctions, and related subjects, including additional sanctions targeting…
On May 12, 2022, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued Syria General License No. 22 (“GL 22”), authorizing certain activities in particular sectors of the Syrian economy that are otherwise prohibited under the Syrian Sanctions Regulations (31 CFR Part 542, “SSR”) in specified regions of Syria not controlled by the Assad regime. According to the US Statement Department’s press release, GL 22 was issued in support of the Biden Administration’s…
On November 26, 2021, the US Treasury Departmentās Office of Foreign Assets Control (āOFACā) published a final rule amending the Syrian Sanctions Regulations (āFinal Ruleā). The Final Rule expands the existing general license at Ā§ 542.516 (the āGeneral Licenseā) to authorize nongovernmental organizations (āNGOsā) 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…