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Case No. SY-2018-354486-1
[***]
Dear [***]
This is in response to the request dated June 14,2018, and supplemental information provided July 1, 2018 (collectively, the “Application”), to the Office of Foreign Assets Control (OFAC), for a license authorizing [***] to transfer the contents of your deceased mother’s Account No. [***] to your [***] account. You have indicated the approximate value of the account was $28,000 and your share would be 38%, that your mother died on [***] and that the Sharia Court ordered distribution of your mother’s estate was to you (the son), a daughter, a grandson, and a granddaughter. You have also indicated that you are the only U.S. beneficiary and the others live in Damascus, Syria.
The Syrian Sanctions Regulations, 31 C.F.R. Part 542 (SySR), block all property and interests in property that are in or...
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1) Applicant sought authorization with respect to a decedent’s account, which appears to have been a U.S.-based account, and more specifically with respect to the distributions from the account to a U.S. beneficiary and others in Syria. OFAC concludes that “in compliance with the requirements of the SySR, [U.S. bank] is authorized to close your mother’s personal, non-commercial account and remit the contents to authorized beneficiaries, as set forth in the Sharia Court Order, who are resident in the United States and/or Syria in accordance with the general license at section 542.515 of the SySR.” 542.515 is the “operations of accounts” GL, which provides that “operation of an account in a U.S. financial institution for an individual in Syria…is authorized, provided that transactions processed through the account [a]re of a personal nature...