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

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TURBOFAC Commentary (640 words)

Notes:

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 Compare the structure of this to the way in which the now-repealed Sudanese Sanctions Regulations had an exemption for certain "Specified Areas of Sudan" [1].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 within the scope of the prohibitions of the SySR, meaning that all transactions "ordinarily incident" to those transactions are authorized by 542.404 of the SySR.

[1] https://www.govinfo.gov/content/pkg/CFR-2010-title31-vol3/xml/CFR-2010-title31-vol3-part538.xml#seqnum538.212

2) Note to paragraphs (a) and (b) is helpful, and of cross-programmatic concern (see also FAQ # 1044). It provides added confirmation for the proposition that "the processing or transfer of funds on behalf of third-country...