In a new FAQ, OFAC clarified that the Federal government, the United Nations, and their employees, contractors and grantees can undertake stabilization and early recovery-related efforts and transactions in Syria under Syrian Sanctions Regulations (SySR).
OFAC explained the scope of authorizations under the SySR and stated that U.N. and U.S. government grantees or contractors must provide a copy of their grant or contract to a U.S. person (e.g., a U.S. financial institution) before that U.S. person engages in any transactions related to stabilization and early recovery-related efforts in Syria. OFAC also explained that non-U.S. persons and entities engaging in or facilitating stabilization and early recovery-related efforts in Syria do not risk triggering U.S. secondary sanctions under the Caesar Syria Civilian Protection Act of 2019.
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