US Sanctions Updates 2014
SYRIAN SANCTIONS REGULATIONS - 2 MAY 2014
On 2 May 2014, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) published and made effective a final rule amending the Syrian Sanctions Regulations (“SSR”) and reissuing them in their entirety, so as to incorporate and further define the following executive orders:
Executive Order 13399 of 25 April 2006;
Executive Order 13460 of 13 February 2008;
Executive Order 13572 of 29 April 2011;
Executive Order 13573 of 18 May 2011;
Executive Order 13582 of 17 August 2011;
Executive Order 13606 of 22 April 2012.
The SSR were first published in April 2005, Syria having been the subject of US sanctions since being designated as a State sponsor of terrorism in 1979. The executive orders issued since 2006 have gradually broadened U.S. sanctions against Syria by imposing new asset freezing and other trade prohibitions, whilst OFAC has also published a number of general licences authorising certain otherwise prohibited transactions and activities. These developments had created a complex patchwork of sanctions measures, so the recently revised SSR now set out these measures in a single and up-to-date set of regulations.
The SSR contain interpretive guidance on the various executive orders now in place, including clarifying that the blocking measures apply in relation to any entity in which a Specially Designated National (“SDN”) owns a 50 per cent or greater interest (regardless of whether such entity is itself designated).
In addition to reissuing the SSR, on 8 May 2014, OFAC announced 10 new Syria-related designations, including 6 senior officials of the Syrian Government and 2 Syrian refineries, Banias Refinery Company and Homs Refinery Company. OFAC has also designated a Russian Bank, Tempbank, for providing material support and services to the Government of Syria, including the Central Bank of Syria and SYTROL, Syria’s state oil marketing firm.
Copies of the SSR and an OFAC press release explaining the latest designations can be downloaded from the links set out below.