Date issued: May. 02 2014
Last substantive commentary amendment:
May. 25 2025
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[5-25-25 Update – see comments to Syria General License 25, broadly authorizing many otherwise prohibited Syria-related transactions].
The irregular scope of this provision reflects the division of labor between BIS and OFAC in the administration of the Syria embargo, where BIS regulates exports and re-exports of goods and technology, while OFAC regulates exports of services.
This broad, IEEPA-based service ban is, for practical purposes, extremely similar to the analogous provision of the service component of the export ban in the ITSR (560.204). Given that 560.204 is arguably the single most-frequently interpreted and enforced provision in the entirety of OFAC's sanctions regulations, one should look to the interpretations of...