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…
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 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…
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…