On 2 May 2014, OFAC amended and reissued the Syrian Sanctions Regulations in their entirety. The amended regulations incorporate the blocking prohibitions imposed by several executive orders issued since the date the regulations were last amended. The amended regulations also include the general licences which previously were found only on OFAC’s website. This brings the regulations into line with the current state of the sanctions regime, and it eliminates the confusion that sometimes resulted from the failure of the regulations to reflect the current scope of the sanctions programme.
The new Syria Sanctions Regulations set out for the first time the “50% rule”. OFAC has in the past stated that it would explicitly incorporate the rule in future regulations, and the new Syria Sanctions Regulations appear to mark the first time that OFAC has actually done so.
Separately, on 8 May 2014, OFAC designated six senior officials of the Syrian government, two Syrian refinery companies, a Russian bank and a senior executive of that bank under the Syria sanctions programme. The government officials were designated pursuant to E.O. 13573 (blocking property of designated senior officials of Syria) and include an advisor to President Bashar Al-Assad, Brigadier General Bassam Al-Hassan, whom OFAC alleges is involved in the Syrian government’s development of non-conventional weapons and missiles. The designated bank, Tempbank, based in Moscow, Russia, is alleged to have provided millions of dollars in cash to the Syrian government as well as to have facilitated transactions on behalf of the Central Bank of Syria and SYTROL, a Syrian state oil company sanctioned by the US and EU. OFAC stated that Mikhail Gagloev, the Chairman of Tempbank’s Management Committee, was designated for acting on behalf of Tempbank, including personal travel to Damascus to conduct business with the Syrian regime on behalf of Tempbank. Both Tempbank and Mr. Gagloev were designated pursuant to E.O. 13582, which allows blocking of property of persons found to have “materially assisted” the government of Syria.