General Note on the Syrian Sanctions Regulations and the Relationship Between the Authorities Underlying the Regulations (System Ed. Note)

Last substantive commentary amendment:
Jul. 04 2025

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TURBOFAC Commentary (2231 words)

General Note on the Syrian Sanctions Regulations and the Relationship Between the Authorities Underlying the Regulations (System Ed. Note)

* 2025-7-3 update - see comments to the EO issued June 30, 2025, which “revokes the…six E.O.s that form the foundation of the Syrian Sanctions Program and terminates the national emergency underlying those E.O.s, effective July 1, 2025” (FAQ # 1220).

*Note: This General Note has not been updated since the Dec. 20, 2019 passage of the Sec. 7401 et seq. of the FY 2020 NDAA (“Caesar Syria Civilian Protection Act of 2019”). See comments to that portion of the FY 2020 NDAA for further discussion of the secondary sanctions contained in the Caesar Act. On 6-5-24, OFAC implemented the Caesar Syria Civilian Protection Act of 2019 and two other Syria-related statutes into...