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Syria

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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…

On 14 October 2019, the Dutch government announced that on 11 October 2019, the government decided, in response to the Turkish invasion of northern Syria, to tighten Dutch arms export policy with regard to Turkey. Until further notice, all new license applications for the export of military goods to Turkey will be held and no new licenses will be issued. Other EU partners, such as France, Germany, Sweden, Finland, Norway and Belgium, have also tightened their national…

On 14 October 2019, the Council of the EU announced that it has extended restrictive measures by the EU addressing the use and proliferation of chemical weapons until 16 October 2020. These sanctions, which consist of a travel ban to the EU and an asset freeze for persons, as well as an asset freeze for entities, currently apply to nine persons – five linked to the Syrian regime and four involved in the Salisbury attack…

On October 10, 2019, the Department of the Treasury 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 Treasury, the following countries require or may require participation in, or cooperation with, an international boycott: Iraq, Kuwait, Lebanon, Libya,…

On February 6, 2019, 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 Treasury, the following countries require or may require participation in, or cooperation with, an international boycott (within the meaning of section 999(b)(3)…

On May 16, 2018, the Department of the Treasury published in the Federal Register, in accordance with section 999(a)(3) of the Internal Revenue Code of 1986 (IRC), 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 IRC). On the basis of the best information currently available to Treasury, the following countries require or may require participation in, or…

On May 10, 2018, the Department of State published in the Federal Register a notice [Public Notice: 10407] that a determination has been made that a number of foreign persons have engaged in activities that warrant the imposition of measures pursuant to Section 3 of the Iran, North Korea, and Syria Nonproliferation Act (the “Act”; Pub. L. 109–353).

On May 10, 2018, the Federal Register published Presidential Notice of May 9, 2018 – Continuation of the National Emergency With Respect to the Actions of the Government of Syria, which continues for an additional year the national emergency first declared on May 11, 2004 in Executive Order (EO) 13338. EO 13338 authorized the blocking of property of certain persons and prohibited the exportation or reexportation of certain goods to Syria. The national emergency was modified in scope and relied upon for additional steps taken in EO 13399 of April 25, 2006, EO 13460 of February 13, 2008, EO 13572 of April 29, 2011, EO 13573 of May 18, 2011, EO 13582 of August 17, 2011, EO 13606 of April 22, 2012, and EO 13608 of May 1, 2012.