Case No. SY-2020-370755-1

Date issued: Apr. 09 2021

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TURBOFAC Commentary (242 words)

Notes:

1) The SySR contain no broad prohibition on the importation of goods or services from Syria, but as a practical matter, the importation of goods from Syria entails the exportation of services, e.g. “financial services” in the form of payments, and for that reason 542.530 authorizes “[a]ll transactions otherwise prohibited by §542.207 that are ordinarily incident to an importation into the United States from Syria, directly or indirectly, of goods technology, or services, are authorized, provided the importation is not from or on behalf of, directly or indirectly, a person whose property and interests in property are blocked pursuant to §542.201(a).” Of note the “Government of Syria” is blocked pursuant to 542.201, and at the time of the request for guidance and OFAC’s response, Aleppo was controlled by the Government of Syria (see