OFAC FAQ (Current) # 885 - Syria Sanctions

Date issued: Apr. 05 2021

TURBOFAC Commentary (128 words)

Notes:

1) Syria-related FAQ 884 and FAQ 885 were issued simultaneously on April 5, 2021.

2) This FAQ does not appear to provide much in the way of "interpretive guidance." The statements concerning the non-sanctionablity of activities otherwise authorized for U.S. persons under 542.510 and 542.525 are applications of the principle set out in FAQ # 884 (With respect to non-U.S. persons, OFAC will not consider transactions to be “significant” for the purpose of a sanctions determination under the Caesar Act if U.S. persons would not require a specific license from OFAC to participate in such a transaction). Refer generally to General Note on "Counterfactual Secondary Sanctions and Derivative Designation Safe Harbors" in Certain OFAC Guidance and FAQs (System Ed. Note).