Syria General License 22 - Authorizing Activities in Certain Economic Sectors in Non-Regime Held Areas of Northeast and Northwest Syria

Date issued: May. 12 2022

Last substantive commentary amendment:
Jun. 06 2024

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TURBOFAC Commentary (882 words)

Notes:

[UPDATE - On 6-5-24, OFAC implemented Syria General License 22 into the ITSR at 542.533 and the List of Areas of Northeast and Northwest Syria in Which Activities are Authorized by 31 CFR 542.533. See comments to Syria General License 22. Nothing about the implementation altered or otherwise clarified the scope of the GL as it had previously existed.]

1) This GL effectively carves out certain regions of Syria from the otherwise broad embargo applicable to that country. Compare the structure of this to the way in which the now-repealed Sudanese Sanctions Regulations had an exemption for certain "Specified Areas of Sudan" [1]. This is much different, since all transactions involving the covered "Non-Regime Held Areas of Northeast and Northwest Syria" are...