Statements of Licensing Policy - On Activities Related to The Telecommunications And Agricultural Sectors Of Syria And Petroleum And Petroleum Products of Syrian Origin For The Benefit of The National Coalition Of Syrian Revolutionary And Opposition Forces or its Supporters

Date issued: Jun. 12 2013

TURBOFAC Commentary (155 words)

Note:

1) This SLP was issued before the 2014 amending and reissuing of the Syrian Sanctions Regulations. Its contents have been implemented in the CFR at sections 542.527 ("Policy on activities related to the telecommunications sector of Syria), 542.528 "Policy on activities related to the agricultural sector of Syria" and 542.529 "Policy on activities related to petroleum and petroleum products of Syrian origin for the benefit of the National Coalition of Syrian Revolutionary and Opposition Forces." The SLP is notable for the bit suggesting that all applicants should provide "information describing due diligence mechanisms to verify that neither the Government of Syria nor any other person whose property and interests in property are blocked is receiving any benefits from [licensed] transactions." This is rarely made explicit, but seems good practice in all contexts in which a transaction subject to discretionary licensing entails an apparent diversion risk related to a particularly sensitive entity.