938. What early-recovery-related transactions and activities are nongovernmental organizations (NGOs) authorized to engage in pursuant to the general license (GL) at § 542.516 of the Syrian Sanctions Regulations (SySR), as amended on November 26, 2021?
The GL at § 542.516 of the SySR authorizes NGOs to engage in activities in support of certain not-for-profit activities in Syria, including: humanitarian projects that meet basic human needs; democracy-building; education; non-commercial development projects directly benefitting the Syrian people; and the preservation and protection of cultural heritage sites. This includes early-recovery-related transactions and activities by NGOs in support of transactions and activities that fall within the categories listed above, including:
• the provision of healthcare and health-related services (such as the restoration of health facilities; the distribution of medical equipment, supplies, and pharmaceuticals; and technical training for and supervision of healthcare workers);
• the provision of educational support and training services (such as the rehabilitation of local schools, the provision of training and equipment support to local educators, training and equipment support to local officials on the operations and management of critical infrastructure, and the provision of vocational and business management training);
• the provision of agricultural-related services (such as the refurbishment of mills, silos, and bakeries to improve food security; the provision of veterinary health services and pharmaceuticals to promote the health of livestock; and training and distribution of agricultural related items); and
• activities related to shelter and settlement assistance, and clean water assistance (such as the rehabilitation and restoration of conflict-damaged water systems, sanitation, and hygiene infrastructure; supplying associated spare parts, training, and support for maintenance of equipment; and rehabilitation of irrigation pumps and canals).
For transactions and activities not otherwise authorized or exempt from sanctions, OFAC considers license requests on a case-by-case basis. Individuals, NGOs, companies, or financial institutions with questions about engaging in or processing transactions or activities related to this authorization can contact OFAC’s Sanctions Compliance and Evaluation Division most efficiently via email at [email protected]. Sanctions Compliance and Evaluation may also be reached via phone at (800) 540-6322 or (202) 622-2490.
Date Released
November 24, 2021
1) This GL was issued concurrently with OFAC's announcement of a revised 542.516 of the SySR. The FAQ provides useful guidance on the scope of what is covered by 542.516. The face of 542.516 uses language to describe the covered NGO-related activities that appears in several other NGO-related GLs, so the FAQ may be considered to have significant cross-programmatic implications. See also FAQ # 926, appearing to interpret “activities to support humanitarian projects and to meet basic human needs” in a way that should have interpretive significance for this provision.
2) Refer to 542.516 for detailed comments on that provision.