On January 15, 2021, the Department of Commerce’s Bureau of Industry and Security (BIS) issued an interim final rule implementing further provisions of the Export Control Reform Act of 2018 by: (i) imposing additional export license requirements under the Export Administration Regulations (EAR) in connection with certain military-intelligence end uses and end users; (ii) clarifying
Syria
OFAC Formally Places the Central Bank of Syria on the SDN List
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…
State Department Imposes Export and Other Restrictions on Chinese and Russian Entities for Transfers of Controlled Items to Iran, North Korea and Syria
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On November 25, 2020, the State Department issued a Federal Register Notice announcing the imposition of nonproliferation measures against certain Chinese and Russian entities for the transfer of goods, services, or technology controlled under multilateral control lists (Missile Technology Control Regime, Australia Group, Chemical Weapons Convention, Nuclear Suppliers Group, Wassenaar Arrangement) or otherwise having the…
OFAC Sanctions Additional Syrian Officials and Entities for Continued Corruption and Human Rights Abuses
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On September 30, 2020, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned three Syrian individuals and 13 entities, placing them on the Specially Designated Nationals and Blocked Persons (SDN) List. These persons and entities are associated with the Fourth Division of the Syrian Arab Army, the Syrian General Intelligence Directorate and…
Treasury and State Departments Continue to Tighten Sanctions Against Syrian President Basher al-Assad’s Regime
On August 20, 2020, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of State sanctioned six Syrian individuals in President Basher al-Assad’s office and the Syrian Ba’ath Party who have contributed to the oppression of the Assad regime. The sanctioned individuals are: (1) President al-Assad’s media adviser, Luna al…
Treasury and State Department Issue Additional Sanctions Against the Regime of Syrian President Bashar al-Assad
On July 29, 2020, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of State sanctioned four Syrian individuals and ten entities. The OFAC designations focus on a key supporter of Syrian President Basher al-Assad for “enriching the Syrian regime through construction of luxury real estate” and for actively…
State Department and OFAC Sanction Syrian Persons and Entities for Continued Disruption and Prevention of Ceasefire in Northern Syria
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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…
OFAC Issues Syria-Related Regulations to Implement 2019 Executive Order Responding to Turkey’s Military Actions
On June 3, 2020, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued new regulations under 31 CFR Part 569 to implement Executive Order (E.O.) 13894 issued by President Trump on October 14, 2019. The President issued E.O. 13894 in response to the situation in and around Syria, in particular, the military…