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Syria Sanctions Compliance Guidelines: Navigating Complex Regulations

As the United States continues to impose economic sanctions on Syria, businesses and individuals must navigate a complex web of regulations to avoid non-compliance. The Office of Foreign Assets Control (OFAC) has issued numerous guidelines, licenses, and FAQs to provide clarity on the Syrian sanctions program.

Guidance for Humanitarian Assistance

The recent Guidance for the Provision of Humanitarian Assistance to Syria highlights the importance of ensuring that humanitarian aid is provided in a manner that does not support or benefit the Syrian government. This guidance outlines specific requirements for humanitarian organizations operating in Syria.

  • Key considerations: Ensure that humanitarian aid does not inadvertently support or benefit the Syrian government.
  • Specific requirements: Review the guidance to determine specific requirements for humanitarian organizations operating in Syria.

Shipping Petroleum: Sanctions Risks and Compliance

The sanctions program also prohibits the shipping of petroleum products to Syria, except under certain circumstances. The Guidance on Sanctions Risks Related to Shipping Petroleum to Syria provides detailed information on the risks associated with such activities and how to comply with regulations.

  • Key considerations: Understand the risks associated with shipping petroleum products to Syria.
  • Compliance steps: Review the guidance to determine specific compliance requirements for shipping petroleum products to Syria.

General Licenses and Specific Licenses

OFAC has issued several general licenses that permit specific activities related to Syria without requiring a license application. These include General License 22, which authorizes certain economic sectors in non-regime-held areas of Northeast and Northwest Syria. Businesses and individuals should review the Syrian Sanctions Regulations to determine if a specific license is required for their activities.

  • General Licenses: Review the list of general licenses issued by OFAC.
  • Specific License Requirements: Determine if a specific license is required for your activities.

Statutory Authorities

The Caesar Syria Civilian Protection Act of 2019 and other statutes provide the statutory authority for the imposition of sanctions on Syria. These laws outline the purposes and objectives of the sanctions program, as well as the penalties for non-compliance.

  • Statutes: Review the relevant statutes that provide the authority for the Syrian sanctions program.
  • Penalties for Non-Compliance: Understand the penalties for non-compliance with the sanctions program.

Regulatory History

A review of the regulatory history related to the Syrian sanctions program reveals a series of amendments and updates to the Syrian Sanctions Regulations. Businesses and individuals should consult the Federal Register notices and Code of Federal Regulations to ensure compliance with current regulations.

  • Regulatory History: Review the list of regulatory changes related to the Syrian sanctions program.
  • Current Regulations: Ensure compliance with current regulations.

UN Security Council Resolutions

The United Nations Security Council has adopted several resolutions related to Syria, including Resolution 1636, which reaffirms the condemnation of terrorism in all its forms. These resolutions provide additional context for the sanctions program and highlight the international community’s commitment to addressing the Syrian crisis.

  • UN Security Council Resolutions: Review the list of relevant UN Security Council resolutions.
  • International Context: Understand the international community’s stance on the Syrian crisis.

Conclusion

Navigating the complex regulations surrounding the Syrian sanctions program requires a thorough understanding of OFAC guidelines, statutory authorities, regulatory history, and UN Security Council resolutions. Businesses and individuals must take steps to ensure compliance with current regulations to avoid non-compliance penalties.