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1212. Are international organizations and nongovernmental organizations authorized to conduct transitional justice activities in Syria?
Yes. Activities to support the rule of law, accountability, and transparency are broadly authorized under the Syrian Sanctions Regulations (SySR), the Global Terrorism Sanctions Regulations (GTSR), and the Foreign Terrorist Organizations Sanctions Regulations (FTOSR), including transactions in support of certain nongovernmental (NGO) activities (31 CFR §§ 594.520; 597.516; 542.516), official business of the U.S. Government (31 CFR §§ 594.518; 597.514; 542.522), and official business of certain international organizations (31 CFR §§ 594.519; 597.515; 542.513) by employees, grantees, or contractors thereof.
For example, the NGO activities general licenses authorize transactions in support of activities to support democracy building, including activities to support rule of law, citizen participation, government accountability and transparency, human rights and fundamental freedoms, access to information, and civil society development projects; and activities to support disarmament, demobilization, and reintegration...
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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 serves as a reminder that GL 24 exists alongside the pre-existing NGO and international organizations GLs, and clarifies, to the extent there is any doubt, that “transitional justice activities” are within the scope of those GLs.