International Trade Law News

Published by Jacobson Burton Kelley PLLC

Updated to include OFAC general licenses 1-6

In response to the recent events in Syria, President Obama issued a statement this morning calling for Syrian President Bashar-Al Assad to "step aside".

In addition, the President today signed an Executive Order (EO 13582) imposing the following additional sanctions on Syria.

• Requires the immediate blocking of all assets of the Government of Syria subject to U.S. jurisdiction.
• Prohibits U.S. persons from exporting or reexporting services to Syria. 
• Prohibits U.S. imports of Syrian-origin petroleum or petroleum products
• Prohibits U.S. persons from having any dealings in or related to Syrian-origin petroleum or petroleum products.
• Prohibits U.S. persons, wherever located, from operating or investing in Syria. 
• Prohibits U.S. persons from approving, financing, facilitating or guaranteeing transactions by foreign person where the transaction by that foreign person would be prohibited if performed by a U.S. person or within the U.S. 

Today's sanctions, which are effective immediately, supplement the recent and past sanctions that have been imposed by the U.S. on Syria. As a result of the Syria Accountability and Lebanese Sovereignty Restoration Act of 2003 (SAA), most exports and reexports of U.S. origin products to Syria have been prohibited since May 2004.

Today’s actions will not impact the export of humanitarian products to Syria, such as medicines, agricultural products and medical devices, which are authorized by the SAA either by general or specific licenses (authorized by OFAC General License No. 4 below).

In addition, the Treasury Department's Office of Foreign Assets Control (OFAC) added the following energy companies in Syria to the List of Specially Designated Nationals (SDN List):

• The General Petroleum Corporation: The state-owned company that controls Syria’s oil and gas industry and is responsible for the exploration, development and investment of Syria’s oil and gas exploration activities.
• Syrian Petroleum Company: Responsible for upstream oil production and development in Syria.
• Syrian Company for Oil Transport: Manages Syria’s domestic pipeline system and is responsible for transporting all Syrian crude and petroleum products. Syrian Company for Oil Transport manages Syria’s three major oil export/import terminals: Baniyas, Tartous and Latakia.
• Syrian Gas Company: Responsible for processing, transporting and marketing Syria’s natural gas.
• SYTROL: Syria’s state oil marketing firm that is responsible for selling Syrian crude to foreign buyers.

This afternoon, OFAC issued the following six general licenses relating to transactions with Syria:

• General License 1 - Authorizing certain goods or services to Syrian Diplomatic Missions in the United States
• General License 2 - Authorizing the provision of certain legal services with respect to Syria​ (however, payment of legal fees and related expenses must be specifically licensed)
• General License 3 - Entries in certain accounts for normal service charges authorized with respect to Syria​ (authorizes financial institutions to normal service charges on blocked accounts)
• ​General License 4 - Exportation or reexportation to Syria of items subject to the Export Administration Regulations; and exportation or reexportation of services ordinarily incident to exportations or reexportations of items licensed or otherwise authorized and related services​
• ​General License 5 - Exportation of certain services incident to Internet-based communications authorized​ (authorizes services, such as instant messaging, social networking, web browsing and blogging, as long as they are no cost to the user, subject to certain conditions)
• ​General License 6 - Noncommercial, personal remittances authorized​ (authorizes banks, money transmitters and brokerage firms to process fund transfers involving non commercial personal remittances only)

The full text of these general licenses can be found here.

Labels: OFAC, Sanctions; Syria