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31 CFR § 542.207 - Prohibited exportation, reexportation, sale, or supply of services to Syria.

Date issued: May. 02 2014

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§542.207 Prohibited exportation, reexportation, sale, or supply of services to Syria.
Except as otherwise authorized, the exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of any services to Syria is prohibited.

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TURBOFAC Commentary (381 words)

Notes:

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 that provision for guidance on the manner in which OFAC is likely to interpret this provision (note that 542.405, interpreting...