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Financial Services Law Insights and Observations

OFAC sanctions Syrian officials and entities

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

Financial Crimes

On July 28, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Orders 13894 and 13572 against eight Syrian prisons run by the Assad regime’s intelligence apparatus, as well as five senior security officials of regime entities that control these detention facilities. A Syrian armed group and two of the group’s leaders were also sanctioned. “Today’s designations promote accountability for abuses committed against the Syrian people and deny rogue actors access to the international financial system,” OFAC Director Andrea M. Gacki stated. “This action demonstrates the United States’ strong commitment to targeting human rights abuses in Syria, regardless of the perpetrator.” As a result of the sanctions, all property and interests in property belonging to the sanctioned persons are blocked, and “any entities that are owned, directly or indirectly, 50 percent or more by one or more blocked persons are also blocked.” OFAC’s announcement further noted that OFAC regulations “generally prohibit” U.S. persons from participating in transactions with the designated persons unless exempt or otherwise authorized by a general or specific license.

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