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231. Can U.S. NGOs deliver humanitarian assistance directly to Syria?
Yes. U.S. NGOs may provide services to Syria in support of humanitarian projects in Syria as authorized by § 542.516 of the Syrian Sanctions Regulations. NGOs carrying out activities funded by the U.S. government, as described in § 542.522, or international organizations, as described in § 542.513, may also rely on those respective authorizations for their activities. Additionally, NGOs may also rely on the authorization in § 542.533 for activities in certain economic sectors in non-regime held areas of Northeast and Northwest Syria. However, other U.S. government authorities, including the Department of Commerce, Bureau of Industry and Security (BIS) export requirements, may apply to the delivery of humanitarian assistance to Syria. In particular, BIS maintains comprehensive restrictions on the export or reexport to Syria of items (commodities, software, and technology) subject to the Export Administration Regulations, 15...
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1) On 6-5-24, OFAC amended FAQ # 231 to (i) update the reference from “OFAC General License No. 11” to 542.516, (ii) specify that NGOs can rely on “official business” GLs or the “non-regime held areas” GL where the NGO GL at 542.516 doesn’t apply.
2) It is notable that OFAC uses “activities [being] funded” by the USG and international organizations as shorthand for such activities qualifying for the “official business” GLs.
3) See generally General Note on GLs Authorizing Transactions of and Related to Nongovernmental Organizations (NGOs) (System Ed. Note).