OFAC Regulatory Provisions - 31 CFR § 542.209 - Prohibited transactions or dealings in or related to petroleum or petroleum products of Syrian origin.

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TURBOFAC Commentary (211 words)

Notes:

1) OFAC has issued no guidance on this provision in particular, and it has resulted in no enforcement actions to date, but it should be assumed that the range of activity in which one may engage with respect to these items is roughly equivalent to what it would be if the property were blocked. "Dealing in" would be defined very broadly. The difference here would be that, these items themselves are not blocked, barring an interest by a blocked person. Compare 560.206, and interpretations thereof, prohibiting dealings in Iranian origin goods.

2) 542.314 provides that "The term petroleum or petroleum products of Syrian origin means petroleum or petroleum products of Syrian origin pursuant to Country of Origin definitions of U.S. Customs and Border Protection." This suggests that the U.S. customs rules are also referred to for the determination of whether products have been "substantially transformed' in a third country. See also 031105-FACRL-BU-01 (and comments thereto).

3) "Petroleum" and "petroleum products" are not defined within the , and no guidance is provided on this question.

For guidance, consult definitions in the of "Petroleum" (561.318) "Petroleum products" (561.319) and "Petrochemical products" (561.330). Query whether the SySR prohibitions are generally meant to exclude "Petrochemical products" from within its scope.

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31 CFR § 542.209 Prohibited transactions or dealings in or related to petroleum or petroleum products of Syrian origin.

TURBOFAC Commentary (211 words)