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934. Are the United Nations and the U.S. government permitted to conduct stabilization and early recovery-related activities and transactions involving Syria? Does this apply to their contractors and grantees as well?
Yes. The general license at § 542.513 of the Syrian Sanctions Regulations (SySR) authorizes, subject to certain conditions, the United Nations, including its Programmes, Funds, and Other Entities and Bodies, as well as its Specialized Agencies and Related Organizations, The International Committee of the Red Cross and the International Federation of Red Cross and Red Crescent Societies; and The Global Fund to Fight AIDS, Tuberculosis, and Malaria, and Gavi, the Vaccine Alliance and their employees, contractors, or grantees to engage in all transactions and activities in support of their official business in Syria, including any stabilization and early recovery-related activities and transactions in support of their official business. This authorization applies to all employees, grantees, and...
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FAQ amended on 6-5-24 in light of changes to the “official business” GL at 542.513. Edits were generally just to conform the text of the FAQ to the new terms of 542.513, OFAC also changed the secondary sanctions risk paragraph such that “engaging in the above activities that are authorized or exempt for U.S. persons under the SySR” was changed to “engaging in the above activities for which a U.S. person would not require a specific license”. This is to conform with 542.414. OFAC also added a reference to the GL at 542.533.
Note that the comments below appear as they did prior to the 6-5-24 amendment.
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1) In general, this FAQ appears to be of the genre of FAQs issued in response to general inquiries...