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Syria

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On April 8, 2021, the US Treasury Department published an updated List of Countries Requiring Cooperation With An International Boycott (the “Treasury List”). Significantly, Treasury announced that it had removed the UAE from the Treasury List following the UAE’s repeal of its law requiring participation with the Arab League Boycott of Israel and subsequent implementation of the new policy. In connection with its establishment of full diplomatic ties with Israel last year under the UAE-Israel Abraham Accords,…

The UK has designated six individuals as subject to financial sanctions and asset freeze measures under the Syria (Sanctions) (EU Exit) Regulations 2019 (S.I. 2019/792). The designated persons are: Muhammad Bara AL-QATIRJI,Faisal AL-MIQDAD,Luna AL-SHIBL,Malik ALIAA,Yasser Hussein IBRAHIM,Zaid SALAH. Separately, two entries under the UK’s Iran (Nuclear) financial sanctions regime have been amended. These entries have been added to the UK sanctions list and to the Office of Financial Sanctions Implementation’s Consolidated list of financial sanctions targets.

On 12 March 2021, the Official Journal published Commission Implementing Regulation (EU) 2021/442 of 11 March 2021 making the exportation of certain products subject to the production of an export authorisation, which requires an export authorisation to export (or re-export after such goods have been subject to manufacturing operations including filling and packaging within the customs territory of the Union) vaccines against SARS-related coronaviruses (SARS-CoV species) currently falling under CN code 3002 20 10, irrespective of their packaging…

On December 22, 2020, the US Treasury Department’s Office of Foreign Assets Control (OFAC) formally added the Central Bank of Syria (“CBOS”) to the List of Specially Designated Nationals and Blocked Persons (the “SDN List”) along with certain high-ranking officials in the Syrian government and affiliated entities. Concurrent with OFAC’s designations, the US State Department (State Department) designated six Syrian individuals pursuant to Section 2 of Executive Order 13894, “Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation…

On October 13, 2020, the Treasury Department published in the Federal Register a current list of countries which require or may require participation in, or cooperation with, an international boycott (within the meaning of section 999(b)(3) of the Internal Revenue Code of 1986). On the basis of the best information currently available to the Department of the Treasury, the following countries require or may require participation in, or cooperation with, an international boycott: Iraq, Kuwait,…

On 15 July 2020, the U.S. and Gulf Cooperation Council (“GCC”)-led Terrorist Financing Targeting Center (“TFTC”) designated six targets affiliated with the Islamic State of Iraq and Syria (“ISIS”), including an entity allegedly posing as a charity (and its director) based in Afghanistan that allegedly provided support to ISIS’ branch in that country, ISIS-Khorasan (“ISIS-K”). The entities that were designated are: Al Haram ExchangeTawasul CompanyAl-Khalidi ExchangeNejaat Social Welfare Organization Five of these targets (which includes…

On June 3, 2020, the US Treasury Department’s Office of Foreign Assets Control (OFAC) issued new Syria-Related Sanctions Regulations (the “Regulations”), effective June 5, 2020 (when published in the Federal Register), to implement Executive Order 13894 (“EO 13894”) issued by the President on October 14, 2019 in light of Turkey’s military actions in Syria. The Regulations are a codification of EO 13894 and do not represent new sanctions against Syria. They are also separate from US comprehensive…

On May 14, 2020, the US Department of State, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC), and the US Coast Guard issued guidance to the private sector aimed at preventing deceptive shipping practices used in sanctions evasion, smuggling, facilitation of terrorism, and other criminal activity (the “Advisory”). The Advisory focuses on tactics recently used by malign actors to evade sanctions and sets out a non-exhaustive list of best practices companies may wish…

On November 13, 2019, the Bureau of Industry and Security (BIS) published in the Federal Register a final rule [Docket No. 191105-0076] that amends the Export Administration Regulations (EAR) by adding twenty-two entities, under a total of thirty-two entries, to the Entity List. These twenty-two entities have been determined by the US Government to be acting contrary to the national security or foreign policy interests of the United States. These entities will be listed on…

On October 23, 2019, the US Treasury Department Office of Foreign Assets Control (OFAC) announced that it had deleted two Turkish ministries and three Turkish individuals from the list of Specially Designated Nationals and Blocked Persons (“SDN List”). These five parties had been designated to the SDN List on October 14, 2019 pursuant to Executive Order 13894 (EO 13894) for contributing to Turkey’s military offensive in northern Syria. Please see our blog post regarding EO 13894 here. OFAC’s…