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LICENSE No. SY-2015-324638-1
SYRIAN SANCTIONS REGULATIONS
LICENSE
(Issued under the authority of one or more of 50 U.S.C. §§ 1601-51, 1701-06, 22 U.S.C. § 287c, Executive Orders 13338, 13399, 13460, 13572, 13573, 13582, and 13606, and 31 C.F.R. Parts 501 and 542.)
To: Marathon Oil Corporation
c/o [ ]
1152 15th Street, N.W.
Washington, DC 20005-1706
Attn.: [ ], Esq.
1. Based on the requests dated December 9, 2015, and additional correspondences dated February 12, 2018, November 15, 2018, February 6, 2019, and April 8, 2019, on behalf of Marathon Oil Corporation, to the Office of Foreign Assets Control (the “Application”), the transactions described herein are hereby authorized.
2. This License is subject to the condition, among others, that the Licensee(s) comply with its terms and...
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1) As of 2-27-23, these licenses are the only of their kind in the Research System. As evident from the application in the native PDF file (see p. 1), the applicant indirectly owned (i) 50% of one Syrian entity, of which the other 50% was owned by a blocked entity owned by an entity meeting the definition of Government of Syria, and (ii) 100% of a Swiss entity that was the owner of the applicant’s stake in the blocked Syrian joint venture. According to the application, the two entities were “dormant”, with no assets (except, in the case of the Swiss entity, its ownership interest in the Syrian entity).
2) According to the application, “[t]he apparent need for a license from [OFAC] is occasioned by [U.S. person applicant’s] need to interact with [Syrian Petroleum Company] (a blocked person) and other Syrian persons -including the Syrian government and...