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.