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 31 C.F.R. Part 542.
On October 14, 2019, two Turkish government ministries and three senior Turkish government officials were briefly added to the Specially Designated Nationals and Blocked Persons List (“SDN List”) pursuant to EO 13894, but they were removed on October 23, 2019. For more information on these designations, please see our blog post here. To date, the only remaining party on the SDN List designated under EO 13894 is a Syrian government official designated in March 2020 for playing a role in the “the violence and the disastrous humanitarian crisis in northern Syria” (see here and here).
EO 13894 remains in effect and provides the Secretary of Treasury with ongoing authority to designate parties under EO 13894 and impose secondary sanctions on any party that has materially assisted, sponsored, or provided financial, material, or technological support, goods or services to any person designated under EO 13894. Any new parties designated under EO 13894 will include the [SYRIA – E.O. 13894] tag on the SDN List. OFAC intends to supplement these regulations with a more comprehensive set of regulations. That process may include additional interpretive and definitional guidance, general licenses, and statements of licensing policy.