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1207. What types of transactions are included in the authorization related to Syrian governing institutions in Syria General License (GL) 24 ("Authorizing Transactions with Governing Institutions in Syria and Certain Transactions Related to Energy and Personal Remittances")?
GL 24 authorizes transactions under the Syrian Sanctions Regulations (SySR), the Global Terrorism Sanctions Regulations (GTSR), and the Foreign Terrorist Organizations Sanctions Regulations (FTOSR).
GL 24 generally authorizes the following transactions, with the exclusion of military or intelligence entities or those acting for or on their behalf:
• providing services to, or paying for services received from, Syrian governing institutions, such as the Ministry of Health, the Ministry of Education, or the Ministry of Water Resources, even if the ministry or leadership of the institution is blocked;
• payment of taxes, fees, or import duties to Syrian governing institutions, even if the ministry or leadership is blocked;...
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1) On 1-6-25, OFAC issued Syria GL 24 and related FAQs FAQ # 1205, FAQ # 1206, FAQ # 1207, FAQ # 1208, FAQ # 1209, FAQ # 1210, FAQ # 1211, and FAQ # 1212. These actions were accompanied by the Press Releases entitled “U.S. Treasury Issues Additional Sanctions Relief for Syrian People”, available at https://home.treasury.gov/news/press-releases/jy2770.
2) This FAQ provides essential guidance concerning the types of transactions that qualify for GL 24. Note that the FAQ implies that “paying for services received from, Syrian governing institutions” does not trigger the “new investment” carveout to the GL. See generally comment 3(v) to Syria GL 24.