OFAC FAQ (Current) # 205 - Syria General License No. 11: (NGOs)

Date issued: Jun. 05 2024

Last substantive commentary amendment:
Jun. 06 2024

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TURBOFAC Commentary (64 words)

Notes:

1) On 6-5-24, OFAC amended FAQ # 205 (initially issued on 6-22-2012) in a way that amounted to an effective rewriting of the FAQ.

The current version of the FAQ specifies that “U.S. persons may donate funds to and raise funds on behalf of U.S. and third-country NGOs that engage in authorized activities in Syria”. This is consistent with Guidance for the Provision of Humanitarian Assistance to Syria - Q # 2 (see comments).

The FAQ also reiterates certain aspects of the NGO GL at 560.516 without providing interpretive guidance, but note the statement that “U.S. person individuals are not authorized to transfer funds directly to Syria for the purpose of charitable donations, absent a specific license from OFAC.” Does this imply that non-blocked Syrian NGOs are not “nongovernmental organizations” for purposes of 542.516, even thought 542.516(a)...