Key Notes:

  • Treasury Department’s OFAC imposes sanctions in response to the April 4, 2017 sarin attack on civilians in Khan Sheikhoun, Syria.
  • Sanctions focus on employees of Syria’s Scientific Studies and Research Center, the Syrian government agency responsible for developing and producing non-conventional weapons and the means to deliver them.
  • The action was taken pursuant to Executive Order 13582, which targets the government of Syria and its supporters.

On April 24, 2017, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) implemented further sanctions against Syria and the regime of Bashar al-Assad in response to the April 4, 2017 sarin attack on civilians in Khan Sheikhoun, Syria. In what is one of the largest single sanctions actions and listings in OFAC history, 271 employees of Syria’s Scientific Studies and Research Center (SSRC), the Syrian government agency responsible for developing and producing non-conventional weapons and the means to deliver them, have been placed on the Specially Designated Nationals (SDN) list. These SSRC employees are said to have expertise in chemistry and related disciplines and/or have worked in support of SSRC’s chemical weapons program.

These designations more than double in a single action the number of individuals and entities sanctioned by the United States pursuant to Syria-related executive orders. OFAC stated that these sanctions are “intended to hold the Assad regime and those who support it … accountable for the regime’s blatant violations of the Chemical Weapons Convention and UN Security Council Resolution 2118.”

The Syria sanctions program is already one of the most comprehensive sanctions programs implemented by OFAC. Nevertheless, Secretary of the Treasury Steven Mnuchin stated that the focus on these individuals and SSRC will be impactful. Syria has consistently said that SSRC is a medical and agricultural study agency, while the United States has found that it is a training laboratory for engineers developing chemical and biological weapons. As a result of these sanctions, any property or interest in property of the designated persons in the possession or control of U.S. persons or within the United States must be blocked, and U.S. persons are generally prohibited from dealing with them. Further it is believed that these scientists will now be more limited in their ability to travel and use the world’s financial system. The full list of the 271 individuals can be accessed on Treasury’s website.