Client Alert: OFAC Amends and Reissues Syrian Sanctions Regulations

On May 2, 2014, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC“) issued a final rule amending and reissuing the Syrian Sanctions Regulations, 31 CFR Part 542 (“Regulations“). Since the Regulations were last issued in April 2005, the President has signed six Executive Orders imposing sanctions targeting Syria and applicable to “U.S. persons.” In particular, Executive Order 13582 (“EO 13582”) significantly expanded U.S. sanctions by blocking the Government of Syria and prohibiting, among other things, the provision of services to Syria by “U.S. persons,” resulting in a virtual trade embargo against Syria. For these purposes, “U.S. persons” means U.S. citizens and permanent resident aliens (i.e., “green card” holders), U.S. legal entities and their foreign branches, and persons in the United States. Our previous Client Alert summarizing EO 13582 is available here.

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