OFAC Issues New Syria General License Expanding Permitted Transactions

January 15, 2025

On January 6, 2025, the Office of Foreign Assets Control (“OFAC”) issued General License No. 24 relating to the Syria sanctions framework. General License 24 permits considerable transactions with Syrian-based individuals and entities, but the largest shift is that it also permits transactions with governmental entities controlled by designated individuals and entities. General License 24 expires on July 7, 2025, but can be renewed or even terminated earlier. The issuance of General License 24 follows the end of the rule of the Assad Regime following a military offensive by the FTO-designated Hay’at Tahrir al-Sham (“HTS”), and the capture by HTS of Syria’s governing institutions and entities.

Washington, D.C. (January 15, 2025) - On January 6, 2025, the Office of Foreign Assets Control (“OFAC”) issued General License No. 24 relating to the Syria sanctions framework. General License 24 permits considerable transactions with Syrian-based individuals and entities, but the largest shift is that it also permits transactions with governmental entities controlled by designated individuals and entities. General License 24 expires on July 7, 2025, but can be renewed or even terminated earlier. The issuance of General License 24 follows the end of the rule of the Assad Regime following a military offensive by the FTO-designated Hay’at Tahrir al-Sham (“HTS”), and the capture by HTS of Syria’s governing institutions and entities.

General License No. 24 permits a loosening on transactions related to the following:

  1. Noncommercial, personal remittances to Syria including through the Central Bank of Syria;
     
  2. Transactions concerning petroleum products, natural gas, and electricity; and
     
  3. Transactions with the governing institutions, even if some of those governing institutions are controlled by designated individuals and entities.

OFAC also issued a FAQ concerning General License No. 24, which clarifies that the purpose of General License No. 24 is to ensure that sanctions do not impede essential governance-related service in Syria following the departure of the Assad Regime. The FAQ also makes clear that:

Transactions are permitted with and to Syria’s “governing institutions” even if they are involved with HTS, so long as those transactions go to the “governing institution” and not directly to HTS and/or to any other designated individual or entity. There is an exception for transactions concerning military or intelligence agencies. The FAQ provides examples such as:

  • Transacting with the Syrian Ministry of Health or Education even if transacting directly with the leadership of the Ministry is blocked;
     
  • The payment of the salaries of said “governing institutions” as long as the individual payee is not designated on OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List);
     
  • Companies desiring to engage in non-sanctioned activities can pay required customs fees even if those customs fees go to a “governing institution” that is led by a designated entity/individual;
     
  • Transactions in support of the sale, supply, storage, or donation of energy, including petroleum, petroleum products, natural gas, and electricity, to or within Syria;
     
  • International organizations and nongovernmental organizations seeking to engage in activities to support democracy building, including activities to support rule of law, citizen participation, government accountability and transparency, human rights and fundamental freedoms, access to information, and civil society development projects; and
     
  • Activities to support disarmament, demobilization, and reintegration programs and peacebuilding, conflict prevention, and conflict resolution programs.

Key Takeaways: General License No. 24 is one of the broadest licenses that provides exemptions for transacting with Syria-related entities and individuals, but restrictions still exist and violating those restrictions may entail criminal proceedings and/or fines. Syria remains one of the most sanctioned countries, with multiple laws and regulations applicable.

Lewis Brisbois’s attorneys are actively engaged in the wide range of legal issues in this area and are advising clients on managing legal and business risk as events continue to develop at an accelerated pace. For more information, contact the author or editor of this alert. Visit our Ukraine Conflict, International Trade, Export, Import and Investment Controls & National Security Practice page for additional alerts in this area.

Author:

Mamoun Mahayni, Associate

Editor:

Andrew Pidgirsky, Partner and Chair of Ukraine Conflict, International Trade, Export, Import and Investment Controls & National Security Practice