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Financial Services Law Insights and Observations

OFAC sanctions Syrian entities, issues FAQs

Financial Crimes OFAC Department of Treasury Sanctions Syria Of Interest to Non-US Persons OFAC Designations

Financial Crimes

On December 22, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) added several individuals and entities, including the Central Bank of Syria (CBoS), to its Specially Designated Nationals and Blocked Persons List related to Executive Order (E.O.) 13894. OFAC also released new Syria Frequently Asked Questions 866, 867, and 868 related to prohibitions applicable to CBoS and allowances for humanitarian assistance to Syria following CBoS’s designation. OFAC clarified, among other things, that “non-U.S. persons who knowingly provide significant financial, material, or technological support to, or knowingly engage in a significant transaction with the Government of Syria, including the CBoS, or certain other persons sanctioned with respect to Syria, risk exposure to sanctions.” With respect to permissible humanitarian assistance, OFAC explained that it “may issue specific licenses to authorize certain transactions involving U.S. persons or the U.S. financial system that may otherwise be prohibited by OFAC sanctions, provided those transactions are in the foreign policy interests of the United States.”