US Issues Syria Sanctions, New FAQs

December 23, 2020 |Sanctions

The U.S. sanctioned eight people and 10 entities for being members of or supporting the Syrian government, the Treasury Department said Dec. 22. The sanctions designate two people and 10 entities by Treasury and six people by the State Department. Treasury also issued three new frequently asked questions related to Syria.

Treasury targeted Lina Mohammed Nazir al-Kinayeh, a senior Syrian government official; her husband, Mohammed Hammam Mohammed Adnan Masouti; and four of their businesses. The agency also sanctioned the Central Bank of Syria and five other business entities belonging to Amer Taysir Khiti, a sanctioned senior Syrian government official. The State Department sanctioned Asma al-Assad, the wife of Syria's President Bashar al-Assad, and members of her immediate family.

Newly issued FAQs 866 and 867 address sanctions implications related to the designation of the Central Bank of Syria. The Syrian Sanctions Regulations block “any contribution or provision of funds, goods, or services” involving the bank, including those that involve the “export, reexport, sale, and supply of services to Syria.” But Treasury said general and specific licenses are available, including those related to humanitarian assistance, including the “export of U.S.-origin food and most medicines.”

Treasury also said it will not consider transactions by non-U.S. persons involving the bank to be sanctionable “if U.S. persons would not require a specific license from [the Office of Foreign Assets Control] to participate in such a transaction,” or if the transactions would qualify for a general license. “OFAC remains committed to ensuring that humanitarian assistance can flow to the people of Syria,” the agency said.

In FAQ 868, OFAC clarified that non-U.S. persons do not risk sanctions exposure for “engaging in humanitarian-related transactions” with Polymedics LLC and Letia Co. -- two businesses owned by al-Kinayeh and Masouti -- as long as those transactions would normally be exempt or qualify for a general license.