Case No. SY-219-1

Date issued: Mar. 29 2013

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TURBOFAC Commentary (1022 words)

Notes:

1) BACKGROUND

At the time this guidance letter was drafted, the Syrian Sanctions Regulations (31 CFR Part 542) only incorporated the limited blocking prohibitions of EO 13338 (for the regulations as they then existed, see https://www.govinfo.gov/content/pkg/CFR-2013-title31-vol3/xml/CFR-2013-title31-vol3-part542.xml).

By the time this guidance letter was drafted, Syria was subject to sanctions imposed in six further executive orders, (Executive Order 13399 of April 25,2006 Executive Order 13460 of February 13,2008 Executive Order 13572 of April 29,2011 Executive Order 13573 of May 18, 2011 Executive Order 13582 of August 17, 2011 Executive Order 13606 of April 22,2012). Most significantly, EO 13582 blocked the entirety of the Government of Syria, and EO 13582 also prohibited the exportation of all services to Syria. However, there had not been...