On February 21, 2023, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued OFAC Compliance Communique: Guidance on Authorized Transactions Related to Earthquake Relief Efforts in Syria (“Guidance”). The Guidance responds to specific questions OFAC received related to earthquake relief efforts in Syria and explains how to provide humanitarian assistance to the Syrian people in compliance with US sanctions.

The Guidance follows Syria General License 23, issued by OFAC on February 9, 2023, which authorized all transactions related to earthquake relief that would otherwise be prohibited by the Syrian Sanctions Regulations. Please see our blog post on Syria General License 23 here.

In addition, on February 27, 2023, OFAC issued a humanitarian assistance fact sheet, Supplemental Guidance for the Provision of Humanitarian Assistance.  This fact sheet supplements OFAC’s 2014 Guidance Related to the Provision of Humanitarian Assistance by Not-for-Profit Non-Governmental Organizations to address the general licenses that OFAC added or revised on December 21, 2022 to implement the UN Security Council Resolution (UNSCR) 2664.  These December 2022 general licenses provided authorizations in 4 categories: (i) the official business of the US Government, (ii) the official business of certain international organizations and entities, (iii) transactions incident to certain humanitarian activities by NGOs, and (iv) the provision of agricultural commodities, medicines and medical devices to individuals in personal, non-commercial quantities.

Author

Paul Amberg is a partner in Baker McKenzie’s Madrid office, where he handles international trade and compliance issues. He advises multinational companies on export controls, trade sanctions, antiboycott rules, customs laws, anticorruption laws, and commercial law matters. Paul helps clients assess and address compliance risks presented by export controls, trade sanctions, antiboycott rules, customs laws, and anticorruption laws. His practice especially focuses on internal reviews, voluntary disclosure filings, and enforcement actions brought by, the US Government in relation to the Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR), trade and economic sanctions programs, and US customs laws.

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Ms. Test advices clients on issues relating to licensing, regulatory interpretations, enforcement actions, internal investigations and compliance audits, as well as the design, implementation and administration of compliance programs. She also advises clients on the extra-territorial application of trade compliance-related regulations in cross-border transactions.

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Caroline focuses on all aspects of International Trade law, particularly compliance with US export controls, trade and economic sanctions, and US foreign investment restrictions. She represents clients in national security reviews before the Committee on Foreign Investment in the United States (CFIUS), including CFIUS-related due diligence, risk assessment, and representation before the CFIUS agencies.