Further to our post about General License (GL) No. 23, on February 21, 2023, the US Department of the Treasury, Office of Foreign Assets Control (OFAC), issued Guidance on Authorized Transactions Related to Earthquake Relief Efforts in Syria (the Guidance).  Although it does not appear that OFAC has published the Guidance as part of formal Frequently Asked Questions, affected US persons and non-US persons who are relying on GL 23 should review the Guidance, which provides additional OFAC interpretations about the scope of GL 23 until it is scheduled to expire on August 8, 2023.  More specifically, the Guidance covers topics such as:

(1) donating money and raising funds for earthquake relief efforts in Syria;

(2) sending money to the people of Syria;

(3) sending any goods or providing any services to Syria;

(4) processing financial transactions related to earthquake relief in Syria;

(5) earthquake relief activity or efforts involving the Government of Syria (GOS);

(6) non-governmental organizations providing aid to Syria;

(7) activity by foreign governments in Syria; and

(8) application of US secondary sanctions under the Caesar Syria Civilian Protection Act of 2019.Continue Reading Additional OFAC Guidance and BIS Licensing Policy Statement on Earthquake Relief for Syria

On February 15, 2023, HM Treasury’s Office of Financial Sanctions Implementation (“OFSI”) issued General Licence INT/2023/2711256 (“GL”) in relation to humanitarian activity associated with earthquake relief efforts in Syria and Turkey.  OFSI’s action follows a similar move by OFAC last week, which is discussed in our blog post (here).  On the same day, the Export Control Joint Unit (“ECJU”) also issued General Trade Licence Syria Sanctions – Earthquake Relief Efforts in Syria (“GTL”), to further facilitate humanitarian assistance in relation to the earthquake relief efforts. Continue Reading OFSI and ECJU Issue General Licences for Earthquake Relief in Syria

Recognizing the importance of humanitarian aid to support rescue and recovery efforts in Syria, the US Department of the Treasury, Office of Foreign Assets Control (“OFAC”) issued a new General License on February 9, 2023 focused on the Syrian earthquake.  This new General License supplements existing OFAC regulations and authorizations supporting humanitarian relief in Syria.Continue Reading OFAC Issues General License for Earthquake Relief in Syria

On 29 June 2022, HM Treasury’s Office of Financial Sanctions Implementation (OFSI) announced that a monetary penalty of £15,000 was imposed on 19 May 2022 against Tracerco Limited (Tracerco) for breaches of The Syria (European Union Financial Sanctions) Regulations 2012 (the UK Regulations).  Tracerco is a UK registered company based in the UAE and a subsidiary of Johnson Matthey, also a UK company.

According to OFSI’s penalty report, Tracerco made two payments to Syrian Arab Airlines (SAA) for an employee’s flights home between May 2017 and August 2018.  According to OFSI, the payments, which had a total value of £2,956.43, resulted in funds being made available for the benefit of a person designated under Council Regulation (EU) No 36/2012 (i.e., SAA).  Tracerco booked the flights through a UAE-based travel agency and then refunded the travel agency for the cost of the flights.

The Tracerco case represents the seventh use of OFSI’s civil monetary penalty powers since they were introduced under Part 8 of the Policing and Crime Act 2017 (PACA).  Several useful hints as to OFSI’s enforcement priorities can be discerned from the Tracerco case.Continue Reading UK Oil Services Company Becomes Seventh Company to Receive OFSI Monetary Penalty for Sanctions Breaches