OFAC FAQ (Current) # 227 - Syria General License No. 6

Date issued: Jan. 06 2025

TURBOFAC Commentary (204 words)

Notes:

1) GL 6 has been superseded and implemented in the SySR. See 542.512 "Noncommercial, personal remittances authorized."

2) FAQ amended on 1-6-25 to account for the issuance of Syria General License 24. Notably, the amended FAQ provides that safe harbor language “(may rely on the statements of their customers)” and specifies that the remittance portion of the GL operates such that it authorizes “transactions that are ordinarily incident and necessary to processing the transfer of noncommercial, personal remittances to Syria, including through the Central Bank of Syria, provided that the recipient is not blocked.” This “recipient is not blocked” language is key to the interpretation of the “financial transactions” carveout of the GL, which provides that the GL does not authorize “Financial transfers to any person blocked pursuant to the GTSR…or SySR” (which would include the Central Bank of Syria). As noted in the comments to Syria GL 24, it is unclear whether “recipient” in “provided that the recipient is not blocked” is a reference to ultimate beneficiaries, or ultimate beneficiaries plus beneficiary banks. The GL and FAQ are certainly open to an interpretation that payments to non-blocked “recipients” with accounts at blocked banks are covered by the GL."