Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.
Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).
Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category).
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1) Note Common to All 8-8-23 "Humanitarian Assistance" Guidance Entries
On 8-8-23, concurrent with the expiration of the earthquake-related Syria General License 23, OFAC removed its Guidance on Authorized Transactions Related to Earthquake Relief Efforts in Syria and replaced it (using the same URL) with OFAC Compliance Communique: Guidance for the Provision of Humanitarian Assistance to Syria.
Because OFAC addresses a multitude of authorities in the "Humanitarian Assistance" guidance, and does so in a way that has implications for the scope and operation of such authorities beyond the four corners of the guidance document, we have categorized each of the 25 questions as separate Research System entries. The questions and associated Research System links are as follows:
Guidance for the Provision of Humanitarian Assistance to Syria - Q # 1 - Can I donate money to NGOs in support of humanitarian efforts in Syria?
Guidance for the Provision of Humanitarian Assistance to Syria - Q # 2 - Can I raise funds for humanitarian efforts in Syria through crowdfunding?
Guidance for the Provision of Humanitarian Assistance to Syria - Q # 3 - Are there any caps on fundraising for humanitarian efforts in Syria?
Guidance for the Provision of Humanitarian Assistance to Syria - Q # 4 - Can NGOs engage in activities to support humanitarian projects in Syria? What activities are authorized?
Guidance for the Provision of Humanitarian Assistance to Syria - Q # 5 - Are NGOs authorized to provide humanitarian assistance in areas controlled by the Government of Syria?
Guidance for the Provision of Humanitarian Assistance to Syria - Q # 6 - Are NGOs authorized to provide disaster relief?
Guidance for the Provision of Humanitarian Assistance to Syria - Q # 7 - Can U.S. financial institutions process transactions related to authorized humanitarian assistance by NGOs in Syria?
Guidance for the Provision of Humanitarian Assistance to Syria - Q # 8 - Are NGOs permitted to provide humanitarian aid in areas where sanctioned groups operate?
Guidance for the Provision of Humanitarian Assistance to Syria - Q # 9 - Can NGOs export goods to Syria in support of humanitarian projects?
Guidance for the Provision of Humanitarian Assistance to Syria - Q # 10 - Can U.S. companies provide goods and services to NGOs conducting authorized humanitarian activities in Syria?
Guidance for the Provision of Humanitarian Assistance to Syria - Q # 11 - Can NGOs purchase refined petroleum products of Syrian origin for use in Syria?
Guidance for the Provision of Humanitarian Assistance to Syria - Q # 12 - Are the United Nations and the U.S. government permitted to conduct stabilization and early recovery-related activities and transactions involving Syria? Does this apply to their contractors and grantees as well?
Guidance for the Provision of Humanitarian Assistance to Syria - Q # 13 - May U.S. and non-U.S. persons provide humanitarian assistance to Syria if they are doing so as an employee or contractor of or have received a grant from the United Nations or the U.S. government (including USAID)?
Guidance for the Provision of Humanitarian Assistance to Syria - Q # 14 - May I send money directly to friends and family in Syria?
Guidance for the Provision of Humanitarian Assistance to Syria - Q # 15 - Can U.S. banks and money services business (MSBs) process remittances to Syria?
Guidance for the Provision of Humanitarian Assistance to Syria - Q # 16 - Can I use digital payments, instant payments, or online platforms or services to send authorized noncommercial, personal remittances to friends and family in Syria?
Guidance for the Provision of Humanitarian Assistance to Syria - Q # 17 - May I export or reexport food or medicine to Syria?
Guidance for the Provision of Humanitarian Assistance to Syria - Q # 18 - May I export items other than food and medicine to Syria in connection with humanitarian efforts?
Guidance for the Provision of Humanitarian Assistance to Syria - Q # 19 - Are transactions related to humanitarian efforts in Syria prohibited if they involve the Government of Syria?
Guidance for the Provision of Humanitarian Assistance to Syria - Q # 20 - Am I allowed to pay taxes, tolls, and fees to the Government of Syria in connection with humanitarian efforts?
Guidance for the Provision of Humanitarian Assistance to Syria - Q # 21 - Can foreign governments provide assistance to NGOs operating in Syria for humanitarian efforts without facing exposure to U.S. sanctions, including in Assad regime-held areas?
Guidance for the Provision of Humanitarian Assistance to Syria - Q # 22 - Can foreign governments or commercial entities invest or engage in commercial activity in Syria?
Guidance for the Provision of Humanitarian Assistance to Syria - Q # 23 - Do non-U.S. persons, including NGOs and financial institutions, risk exposure to U.S. sanctions pursuant to the Caesar Act for activities that would be authorized under the Syrian Sanctions Regulations?
Guidance for the Provision of Humanitarian Assistance to Syria - Q # 24 - Does OFAC authorize U.S. persons to engage in construction projects in Syria?
Guidance for the Provision of Humanitarian Assistance to Syria - Q # 25 - May I engage in or fund building safety inspections in Syria?
2) Notes Specific to This Q&A
a) Compare Earthquake Relief Efforts in Syria - Question # 10 (“May I engage in or fund building safety inspections related to the earthquake in Syria” in the context of now-expired Syria GL 23). Here, OFAC confirms that “building safety inspections” can be within the scope of the NGO GL (among others).