PRINT
Case No. SY-219-1
Rachel Bare
Logistics Manager
Makad Food International, LLC
900 Washington Street
Suite 1100
Vancouver, WA 98660
Dear Ms. Bare:
This responds to your letter dated April 22, 2011, on behalf of Makad Food International, Inc. (“Makad”), to the Office of Foreign Assets Control (“OFAC”), requesting confirmation that Makad does not require OFAC authorization to export certain agricultural and food products to Syria.
Executive Order 13582 of August 17, 2011, “Blocking Property of the Government of Syria and Prohibiting Certain Transactions With Respect to Syria” (“E.O. 13582”), blocks all property and interests in property of the Government of Syria. E.O. 13582, § 1(a). E.O. 13582 also prohibits the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a U.S. person, wherever located, of...
Click the appropriate link below for access to this file.
Click the appropriate link below for access to this file.
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...