On February 10, 2023, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License (GL) 23 that authorizes until August 8, 2023 all transactions related to earthquake relief efforts in Syria that would otherwise be prohibited by the Syrian Sanctions Regulations under 31 C.F.R. Part 542. The GL makes clear that it covers the processing or transfer of funds, and in a related press release, OFAC clearly states that, “U.S. and intermediary financial institutions should have what they need in GL23 to immediately process all earthquake relief transactions.”
While general authorizations already existed for most activities in support of humanitarian assistance in Syria, OFAC stated that GL 23 “provides the broad authorization necessary to support immediate disaster relief efforts in Syria.” The press release also notes that the Department of the Treasury “will continue to monitor the situation in Syria and engage with key humanitarian and disaster assistance stakeholders, including [nongovernmental organizations, international organizations], and key partners and allies, to understand emerging challenges they may face in delivery of services.”
It should be noted that while GL 23 does authorize transactions with the government of Syria, it otherwise continues to prohibit any transactions with persons or entities who are blocked and on OFAC’s Specially Designated Persons (SDN) List.
As a reminder, 31 C.F.R. Part 569 under the separate Syria-Related Sanctions Regulations at § 569.510 already authorizes the official business of certain international organizations and certain transactions in support of nongovernmental organizations‘ activities.
UPDATE: On February 21, 2023, OFAC issued a Compliance Guidance with FAQs on how to provide legitimate humanitarian assistance related to earthquake relief to Syria while complying with OFAC sanctions. The FAQs focus mainly on the provision of funds and remittances into Syria as well as providing services to Syria. The guidance also reminds the general public that the Department of Commerce’s Bureau of Industry and Security (BIS) has separate jurisdiction over the export or reexport of most physical items and software to Syria. On February 17, 2023, BIS announced that it would expedite it review of export license applications to both Turkey and Syria that are related to earthquake relief. See Update of February 21, 2023.