31 CFR § 542.510 - Exports or reexports to Syria of items licensed or otherwise authorized by the Department of Commerce authorized; exports or reexports of certain services authorized.

Date issued: May. 02 2014

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TURBOFAC Commentary (320 words)


1) This general license, unique among active sanctions programs, is the result of the quirky nature of the SySR as having an export embargo fully administered by BIS (except with respect to blocked persons). Because there is no .200-level prohibition dealing with exports or ordinary products to non-blocked Syrians, facilitative services such as financial, shipping and insurance services are not eligible for 542.404, which only applies to transactions that are prohibited at the threshold level but then authorized by OFAC, and even if the export requires no license from BIS. See Case No. SY-219-1, in which OFAC clarifies that this GL covers U.S. origin food (even if no BIS license is required to export the food) and that the "processing of...