On December 22, 2020, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) formally added the Central Bank of Syria (CBoS) to the Specially Designated Nationals (SDN) List. While OFAC notes that the bank is “already blocked as meeting the definition of the Government of Syria in [Executive Order] 13582 and the Syrian Sanctions Regulations, 31 C.F.R. Part 542,” this formal listing serves to highlight its blocked status. According to OFAC, CBoS oversees monetary policy in Syria, issues the national currency, regulates the operations of private sector banks and money services businesses, and acts as the fiscal and depository agent of the government of Syria. The CBoS has deep banking ties to Iran, the world’s largest state sponsor of terrorism, and has been an integral part of the regime’s efforts to increase public revenues and prop up the Syrian currency. The Department of the Treasury stated that formal placement on the SDN List “aims to discourage future investment in government-controlled areas of Syria, force the regime to end its atrocities against the Syrian people, and compel its commitment to the United Nations-facilitated process in line with UN Security Council Resolution 2254.”
In addition, OFAC sanctioned a high-ranking official in the Syrian government whose husband is a member of the Syrian People’s Assembly and their business entities.
As a result of this action, all property and interests in property of these entities and persons that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC. Unless authorized by a general or specific license issued by OFAC or otherwise exempt, OFAC’s regulations generally prohibit all dealings by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons. In addition, non-U.S. persons that engage in certain transactions with the persons designated may be exposed to designation. However, OFAC has updated FAQs 867 and 868 pertaining to Syria, stating that despite the placement of CBoS on the SDN List, U.S. and non-U.S. persons may continue to engage with the bank in connection with humanitarian assistance and other authorized trade (i.e., under general and specific licenses).