Sec. 7401 et seq. of the FY 2020 NDAA (“Caesar Syria Civilian Protection Act of 2019”)

Date issued: Dec. 20 2019

Last substantive commentary amendment:
May. 25 2025

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TURBOFAC Commentary (1980 words)

Notes:

[5-25-25 Update – see comments to Syria General License 25, broadly authorizing many otherwise prohibited Syria-related transactions and discussing the 180-day Caesar Act waiver]

[6-6-24 Update – on 6-5-24, the Caesar Act was implemented into the SySR at section 542.201(a)(13). The comments below have not yet been updated to reflect this fact. The SysR implementation was associated with a number of other regulatory additions and changes to accommodate the Caesar Act implementation, including, most significantly, 542.414, which defines “significant transaction” for purposes of the Caesar Act].

[Update - Sec. 5123 of the National Defense Authorization Act for Fiscal Year 2025 (https://docs.house.gov/billsthisweek/20241209/RCP_HR5009_xml%5b89%5d.pdf) extends the sunset provision in the Caesar Act by five years so that the new sunset date is December 31, 2029].

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