31 CFR § 542.211 Exempt transactions.

Date issued: Jun. 05 2024

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TURBOFAC Commentary (2448 words)

Notes:

[6-6-24 UPDATE] On 6-5-24, OFAC amended the SySR to, among other things, implement the prohibitions of three Syria-related statutes, i.e. (i) Section 234 of Countering America's Adversaries Through Sanctions Act, (ii) the Syria Human Rights Accountability Act of 2012 (SHRAA) and (iii) the Caesar Syria Civilian Protection Act of 2019 (Caesar Act).

In conjunction with these developments, OFAC made certain conforming amendments to this “Exempt transactions” provision.

a) First, OFAC added a “United Nations Participation Act” provision (542.211(a)) that is identical to that which appears in other “Exempt transactions” provisions associated with sanctions programs that implement authorities some (but not all) of which are based on UNPA. Compare e.g. 547.206(a) (Congo). Here, EO 13399 is...