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1211. Can foreign governments or companies donate or provide subsidized fuel to Syria without facing exposure to U.S. sanctions?
Yes. Syria General License (GL) 24 authorizes transactions in support of the sale, supply, storage, or donation of energy, including petroleum, petroleum products, natural gas, and electricity, to or within Syria. This may include, for example, the donation of gasoline to Syrian refineries, and power plants.
However, authorizations for this activity under the general license do not relieve persons from compliance with any other laws or requirements of other federal agencies or international organizations. For example, the export or reexport of petroleum, petroleum products, natural gas, and other commodities to Syria may require additional authorization from the Department of Commerce if such items are U.S.-origin or otherwise subject to the Export Administration Regulations (EAR).
Released on Jan 06, 2025
Syria Sanctions
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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) It is unclear why OFAC only offers this secondary sanctions safe harbor guidance in the context of a portion of GL 24, instead of the whole thing. OFAC has provided guidance specifying that, in general, “[f]oreign persons do not risk exposure to U.S. sanctions for engaging in activity for which a U.S....