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Case No. SY-2015-316218-1
Samer Masri
Fundacja Wolna Syria
Chelmska 9/23
00-724 Warsaw
Poland
Dear Mr. Masri:
This is in response to your request of January 16, 2015, as supplemented on February 4, February 27, and June 25, 2015 (the “Application”), on behalf of Fundacja Wolna Syria, an independent NGO in Poland, to the Office of Foreign Assets Control (OFAC), in which you seek authorization to conduct financial transactions in support of humanitarian aid sent to Syria.
The Syrian Sanctions Regulations, 31 C.F.R. Part 542 (SySR), block all property and interests in property that are in or come within the United States, or that are in or come within the possession or control of any U.S. person, including any foreign branch, of the Government of Syria and of certain other designated persons, and...
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1) The Applicant was a small Polish “foundation” focused on fundraising and using the funds to send humanitarian aid to Syria. In the year prior to the January 2015 guidance application, the Applicant had no employees, and had raised around $20.000 and had around $4,000 in cash. (See https://web.archive.org/web/20180831084316/http://wolnasyria.org/images/pdf2/sprawozdanie_z_dzialalnosci_2014.pdf, also in PDF). OFAC determines that the foundation’s “financial transactions in support of humanitarian aid sent to Syria” were capable of fitting within the nongovernmental organizations GL at 542.516. The guidance letter is notable for principally as an example of OFAC regarding a very small non-U.S. person entity as one that qualifies as a “nongovernmental organization” for purposes of the SySR NGO GL. See generally General Note on GLs Authorizing Transactions of and Related to Nongovernmental Organizations...