On May 12, 2022, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Syria General License (“GL”) 22, which authorizes certain transactions, including processing or transfer of funds on behalf of third-country entities, otherwise prohibited under the Syrian Sanctions Regulations (SSR) that are ordinarily incident and necessary to activities in the areas of northeast and northwest Syria (i.e., non-regime held areas, as defined in the Annex to the GL) in agriculture, information and communications, power grid infrastructure, construction, finance, clean energy, transportation and warehousing, water and waste management, health services, education, manufacturing, and trade. This GL provides authorization for certain activities otherwise prohibited by the SSR, including the prohibitions on U.S. persons in engaging in new investments in, or exportation, reexportation, sale, or supply of any services to Syria. GL 22 also authorizes the purchase of refined petroleum products of Syrian origin for use in Syria that is ordinarily incident to the activities described in the GL. GL 22 authorizations exclude any transaction involving any person, including the Government of Syria, blocked pursuant to Syrian Sanctions Regulations and Caesar Syria Civilian Protection Act of 2019.
OFAC issued five frequently asked questions (“FAQs”), FAQs 1041 – 1045, and updated FAQ 884 to reflect the new GL 22. Notably, OFAC explained in the new FAQs that the purpose of GL 22 is to improve the economic conditions in non-regime held areas of Syria and to support ongoing stabilization efforts, and is not intended to remove sanctions on the Assad regime.