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31 CFR § 542.509 Syrian diplomatic missions in the United States.

Date issued: May. 02 2014

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§542.509 Syrian diplomatic missions in the United States.
(a) The provision of goods or services in the United States to the diplomatic missions of the Government of Syria to the United States and to international organizations in the United States and payment for such goods or services are authorized, provided that:
(1) The goods or services are for the conduct of the official business of the missions, or for personal use of the employees of the missions, and are not for resale;
(2) The transaction does not involve the purchase, sale, financing, or refinancing of real property; and
(3) The transaction is not otherwise prohibited by law.
Note 1 to paragraph (a) of §542.509: U.S. financial institutions are reminded of their obligation to comply with 31 CFR 501.603.
Note 2 to paragraph (a) of §542.509: U.S. financial institutions are required to obtain specific licenses to operate accounts for, or extend credit to, the diplomatic missions of the Government of Syria to the United States and to international organizations in the United States.
(b) The provision of goods or services in the United States to the employees of the diplomatic missions of the Government of Syria to the United States and to international organizations in the United States and payment for such goods or services are authorized, provided that:
(1) The goods or services are for personal use of the employees of the missions, and are not for resale; and
(2) The transaction is not otherwise prohibited by law.
Note to §542.509: Nothing in this section authorizes the transfer of any property to the Government of Syria, or any other person whose property and interests in property are blocked pursuant to §542.201, other than the diplomatic missions of the Government of Syria to the United States and to international organizations in the United States.
External link location:
https://www.ecfr.gov/cgi-bin/text-idx?SID=2d5afa2cb880d557cc00ad2dd3cea64a&mc=true&node=pt31.3.542&rgn=div5#se31.3.542_1509

TURBOFAC Commentary (194 words)

Notes:

1) Similar license available in all country-wide embargo programs, but note substantial variances across licenses (515.568, 560.512, 510.510, 542.509).

2) "International organizations" is not defined in the GL or elsewhere in the regulations. In some cases (see e.g. 594.510), a GL referring to "international organizations" specifies that the "United Nations" is all that counts. In other cases (e.g. Venezuela General License 20), "international organizations" extend beyond those that are part of the UN. We would expect this GL to include within its scope the non-UN organizations listed in Venezuela General License 20 (e.g. International Federation of the Red Cross and Red Crescent Societies), but beyond that, it is difficult to determine the full scope of the GL.

3) OFAC appears to consider all sanctioned country diplomat representatives of government missions to be persons that, on a per se basis, "act on behalf of" the blocked governments they represent. This is true even where such persons seek goods and services on their own accounts. See Civil Enforcement Information - TD Bank, N.A..

* Provision amended on 6-5-24 to make non-substantive changes to change references to 542.201(a) from that to just 542.201.