Case No. SY-177
Daniel T. R. Masterson
Executive Director
A Plate for All
1 Phinney St.
Gorham, ME 04038
Dear Mr. Masterson:
This responds to your letter, on behalf of "A Plate for All," received by the Office of Foreign Assets Control ("OFAC") on January 25, 2010, requesting an OFAC license to operate in Syria. You represent in your letter that your company, "A Plate for All," was formed for charitable purposes to provide food aid for displaced peoples. You represent in your letter that "A Plate for All" transfers money to Beirut, where its partner organization, the Greek Orthodox Patriarchate, withdraws the money to pay for food supplies that are distributed to Iraqi refugees located in Syria.
OFAC regulates transactions with Syria pursuant to the Terrorism List Governments Sanctions Regulations, 31...
This guidance letter was issued prior to the Government of Syria becoming blocked (542.201) and prior to the imposition of the prohibition on the exportation of services to Syria (542.207). This guidance letter interprets the generally irrelevant TLGSR, to which Syria remains subject as of 10/26/2021. Of some note, OFAC appears to construe the term “donation to a United States person” to include donations “through” United States person that is destined for a third-country person (i.e. cases where the U.S. person would not ordinarily be regarded as the donee) (596.504(a)(1)).