§542.523 Certain services to the National Coalition of Syrian Revolutionary and Opposition Forces authorized.
(a) Except as provided in paragraphs (b) and (c) of this section, U.S. persons are authorized to export, reexport, sell, or supply, directly or indirectly, to the National Coalition of Syrian Revolutionary and Opposition Forces ("the Coalition") services otherwise prohibited by §542.207.
Note to paragraph (a): See §542.510 for a general license authorizing the exportation and reexportation of certain items and services to Syria.
(b) This section does not authorize:
(1) Any transaction with a person whose property and interests in property are blocked pursuant to §542.201(a); or
(2) The exportation, reexportation, sale, or supply, directly or indirectly, of any services in support of the exportation or reexportation to Syria of any item listed on the United States Munitions List (22 CFR part 121).
(c) Any transfer of funds to or from the Coalition under this section must be conducted through the Coalition's U.S. office through an account of the Coalition at a U.S. financial institution specifically licensed for that purpose by OFAC.
Note to paragraph (c): For additional information on the bank account that is specifically licensed for receipt of funds transfers, please contact the U.S. office of the Coalition at 1101 Pennsylvania Avenue NW., Ste # 6620, Washington, DC 20004, ATTN: OFAC-authorized bank account, or by phone at (202) 800-1130.
Note 1 to §542.523: Financial institutions transferring funds to or from the Coalition pursuant to this section may rely on the originator of a funds transfer with regard to compliance with paragraph (b), provided that the transferring institution does not know or have reason to know that the funds transfer is not in compliance with paragraph (b) of this section.
Note 2 to §542.523: Consistent with sections §542.101 and §542.502, this section does not authorize any transaction prohibited by any part of 31 CFR Chapter V other than §542.207. For example, this section does not authorize any transaction with a person whose property and interests in property are blocked pursuant to §594.201 of this chapter, such as al-Nusrah.
1) As cautioned in Note 2 to §542.523, there are, apart from the parties blocked pursuant to the SySR, entities subject to other sanctions programs for which this GL does not authorize transactions. Al-Nusrah, singled out, is an FTO and SDGT. Given the situation in Syria, private actors availing themselves of this GL should be acutely aware of the government's current diligence expectations and risk tolerance related to potential diversions from entities for which transactions are encouraged to those subject to the terror-based sanctions programs in particular.
2) This GL implements a portion of the "Statements of Licensing Policy - On Activities Related to The Telecommunications And Agricultural Sectors Of Syria And Petroleum And Petroleum Products of Syrian Origin For The Benefit of The National Coalition Of Syrian Revolutionary And Opposition Forces or its Supporters" (still available on OFAC's website).
3) See also 542.529 (Policy on activities related to petroleum and petroleum products of Syrian origin for the benefit of the National Coalition of Syrian Revolutionary and Opposition Forces).