New Syria-Related Sanctions Regulations Issued; Secondary Sanctions Authority Targeting Syria to Take Effect Soon

June 12, 2020

On June 4, 2020, the U.S. Department of the Treasury, Office of Foreign Assets Control issued the Syria-Related Sanctions Regulations.

Not to be confused with the pre-existing Syrian Sanctions Regulations found in 31 C.F.R. Part 542, the SRSR, which are found in 31 C.F.R. Part 569, are intended to implement Executive Order 13894, Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Syria (October 14, 2019; the Executive Order).  We previously wrote about the broad authority to impose sanctions against a wide range of individuals and entities under the Executive Order here.  The impact of the Executive Order and the SRSR will depend, of course, on the scope of the actual sanctions imposed.  As of today, only the current Syrian Minister of Defense is designated on the list of Specially Designated Nationals and Blocked Persons maintained by OFAC pursuant to the Executive Order.

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