31 CFR § 542.523 - Certain services to the National Coalition of Syrian Revolutionary and Opposition Forces authorized.

Date issued: May. 02 2014

TURBOFAC Commentary (173 words)


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).