On June 6, 2024, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) amended the Syrian Sanctions Regulations (“SSR”) to incorporate prohibitions and bases for designations of Specially Designated Nationals contained in several statutes and Executive Orders (“E.O.”), including the Syria Human Rights Accountability Act of 2012, the Countering America’s Adversaries Through Sanctions Act, the Caesar Syria Civilian Protection Act of 2019, and E.O.s issued pursuant to the national emergency declared in E.O. 13338.
Among other changes, OFAC expanded the authorizations provided in the general license at § 542.511 of the SSR for the export of certain internet-based communication services. These changes include listing additional technologies that are deemed incident to the exchange of communications over the internet and expanding the scope of the authorization to cover the provision of services incident to the exportation or reexportation of software or hardware incident to the exchange of communications over the internet.
OFAC also expanded the authorizations in two general licenses regarding humanitarian assistance by certain international organizations and nongovernmental organizations. In the general license in § 542.513 of the SSR, which authorizes the official business of certain international organizations and entities, OFAC identified additional international organizations and entities covered by the general license and removed the requirement that contractors or grantees must provide a copy of their contract or grant. OFAC also revised the general license in § 542.516, which authorizes certain services in support of nongovernmental organizations’ activities, to align the authorizations in such general license more closely with similar authorizations in other OFAC regulations.
In addition, OFAC added § 542.212 to the SSR to implement the restrictions on foreign persons determined to be foreign sanctions evaders pursuant to sections 1 and 5 of E.O. 13608. The names of persons who are determined to be subject to the prohibitions of § 542.212 are published on OFAC’s Foreign Sanctions Evaders (FSE) List, which is accessible via OFAC’s website, and published in the Federal Register.
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