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Financial Services Law Insights and Observations

OFAC authorizes certain transactions to aid Syrian earthquake disaster relief

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

Financial Crimes

On February 9, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued Syria General License (GL) 23 to authorize, for 180 days, all transactions related to earthquake relief efforts that would ordinarily be prohibited by the Syrian Sanctions Regulations (SySR). Specifically, authorizations under GL 23 include “the processing or transfer of funds on behalf of third-country persons to or from Syria in support of” transactions related to earthquake relief efforts in the country. Additionally, “U.S. financial institutions and U.S. registered money transmitters may rely on the originator of a funds transfer with regard to compliance” for transactions related to earthquake relief efforts in Syria, provided that the financial institution does not know or have reason to know that the funds transfer is not related to such efforts. GL 23 does not permit any transactions prohibited under the SySR related to the importation of petroleum or petroleum products of Syrian origin into the U.S., or any transactions involving persons “whose property and interests in property are blocked pursuant to the SySR, other than persons who meet the definition of the term Government of Syria, as defined in section 542.305(a) of the SySR, unless separately authorized.” Additionally, OFAC advised financial institutions and others who may be engaged in disaster relief activities for Syria to contact OFAC directly to seek specific licenses or guidance should they believe their activities are not covered by existing authorizations or exemptions.