On June 26, 2020, the State Department issued a Federal Register notice announcing that it has sanctioned certain Syrian individuals and entities it has determined “are responsible for or complicit in, have directly or indirectly engaged in, attempted to engage in, or financed, the obstruction, disruption, or prevention of a ceasefire in northern Syria” or for otherwise preventing a “political solution to the conflict in Syria.” Accordingly, the State Department has taken the following actions with regard to these persons and entities:
- U.S. government agencies shall not procure, or enter into a contract for the procurement of, any goods or services from the individuals and entities;
- Prohibit any United States financial institution that is a U.S. person from making loans or providing credits to the individuals and entities totaling more than $10,000,000 in any 12-month period, unless the individuals and entities are engaged in activities to relieve human suffering and the loans or credits are provided for such activities;
- Prohibit any transactions in foreign exchange that are subject to the jurisdiction of the United States and in which the individuals and entities have any interest;
- Prohibit any transfers of credit or payments between banking institutions or by, through, or to any banking institution, to the extent that such transfers or payments are subject to the jurisdiction of the United States and involve any interest of the individuals and entities;
- Prohibit any United States person from investing in or purchasing significant amounts of equity or debt instruments of the individuals and entities; and
- Restrict or prohibit imports of goods, technology, or services, directly or indirectly, into the United States from the individuals and entities.
In a parallel action, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) has placed 14 individuals and 21 entities on (and made other related revisions) the Specially Designated Nationals (SDN) List. As a result of this action, all property and interests in property of these persons that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC. OFAC has indicated that any foreign financial institution that knowingly facilitates a significant financial transaction or provides significant financial services for these persons could be subject to U.S. correspondent account sanctions or payable-through account sanctions.