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September 27, 2021

ISTANBUL – Last week, the U.S. Treasury Department’s Deputy Assistant Secretary (DAS) for Strategic Policy Scott Rembrandt held a virtual meeting in Istanbul with representatives from non-governmental organizations (NGOs) engaged in humanitarian assistance for the Syrian people. DAS Rembrandt reinforced the U.S. government’s support for the flow of relief aid to vulnerable populations in the country while also upholding international anti-money laundering and counter terrorist financing (AML/CFT) standards. In a separate meeting, DAS Rembrandt encouraged Turkish financial institutions to adopt a risk-based approach towards implementing AML/CFT obligations and to ensure that NGOs continue to have appropriate financial access to carry out their work.

“The United States remains committed to ensuring that humanitarian assistance from the international community reaches Syrian civilians,” said DAS Rembrandt. “At the same time, the United States will continue to implement and enforce economic and financial pressure on the Syrian regime, which continues to commit abhorrent and egregious human rights abuses and attacks against its own people.”

The United States is focused on deterring the malign activities of Bashar al-Assad, his regime, cronies, and foreign enablers, as well as terrorist groups, including by limiting their ability to access the international financial system and global supply chains. At the same time, the United States remains committed to ensuring that humanitarian assistance from the international community reaches Syrian civilians.

To this end, the United States’ Syria sanctions program contains a number of general licenses related to humanitarian assistance and trade with Syria. For a summary of the most relevant exemptions, exceptions, and authorizations for humanitarian assistance under the Syria and other sanctions programs, please refer to Treasury Department’s OFAC Fact Sheet: Provision of Humanitarian Assistance and Trade to Combat COVID-19.

Additionally, in order to further aid the global fight against COVID-19, Treasury’s Office of Foreign Assets Control (OFAC) issued a time-limited general license in the Syria program, GL 21, which builds upon Treasury’s existing broad authorizations for certain COVID-19-related transactions and activities. This authorization will further help support the critical work of governments, international organizations, and private sector actors, including non-governmental organizations, non-profit organizations, and financial institutions, as well as individuals delivering or facilitating transactions for medical supplies and COVID-19-related assistance to the people of certain sanctioned countries.

Concurrent with this action, OFAC also issued FAQs that provide further clarity on what the COVID-19-related general licenses authorize, OFAC’s due diligence expectations of U.S. financial institutions facilitating activity authorized by the COVID-19-related general licenses, and guidance on non-U.S. persons’ exposure to sanctions risk. Of note, FAQ 911 makes clear that non-U.S. persons do not risk exposure under U.S. sanctions for engaging in certain activities to respond to the COVID-19 pandemic that would be authorized under General License 21 if engaged in by a U.S. person.

Additional guidance and information can be found on OFAC’s website (https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/syria-sanctions). If you have additional questions regarding the scope of any sanctions programs’ requirements, or the applicability or scope of any humanitarian-related authorizations, please contact OFAC’s Sanctions Compliance and Evaluation Division at (800) 540-6322 or (202) 622-2490, or by email at OFAC_Feedback@treasury.gov.