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.


Terry Gilroy is a partner in the New York office of Baker McKenzie and a member of the Compliance and Investigations Practice Group. Prior to joining the Firm in 2018, Terry served as Americas Head of the Financial Crime Legal function at Barclays. Terry advises businesses and individuals on white collar and financial crime issues and has significant experience conducting investigations relating to compliance with the US Foreign Corrupt Practices Act (FCPA) and related bribery and corruption statutes, economic sanctions regulations as administered by the US Department of the Treasury's Office of Foreign Assets Control (OFAC), and the Bank Secrecy Act and related anti-money laundering (AML) regulations and statutes. Terry spent six years on active duty in the United States Army as a Field Artillery officer.


Andrea practices international commercial law with a focus on cross-border transactions including post-acquisition integration IP migrations and technology licensing. She also advises companies on export controls, sanctions, customs and international corporate compliance. Andrea also has an active pro bono practice, including helping organizations with international constitutional matters and victims of domestic abuse.