Syria General License 23 - Authorizing Transactions Related to Earthquake Relief Efforts in Syria (February 9, 2023)

Date issued: Feb. 09 2023

You've hit a wall. Sign in if you have an account, learn more about TURBOFAC and subscription options, or purchase access to the text of the document on this page, the native .pdf file, and the associated TURBOFAC original commentary.
TURBOFAC is a module of the compliance platform OverRuled. To learn more about OverRuled, visit www.overruled.com.

TURBOFAC Commentary (506 words)

Notes:

1) This is unique (and uniquely broad) GL that authorizes "all transactions related to earthquake relief efforts in Syria," with certain limitations. The GL operates concurrently, and overlaps in scope with, GLs such as 542.510 (ag/med exports), 542.516 (NGO-related activities) and Syria General License 22 (broad GL for Activities in Certain Economic Sectors in Non-Regime Held Areas of Northeast and Northwest Syria).

2) There is a notable distinction between the “note” in Syria General License 22 and Syria General License 23, i.e. that the “general license includes the processing or transfer of funds on behalf of third-country persons to or from Syria” (GL 23), as opposed to “the processing or transfer of funds on behalf of third-country entities to or from Syria” (GL 22). Query, does GL 22 really apply only to...