On June 5, 2020, the Department of Treasury, Office of Foreign Assets Control (OFAC), published a final rule (85 FR 34510) establishing the Syria-Related Sanctions Regulations (31 CFR Part 569), which implement Executive Order 13894. The new regulations are in addition to OFAC’s existing Syria Sanctions Regulations (31 CFR Part 542).
Although titled “Syria-Related Sanctions,” the sanctions regulations are targeted at Turkish entities involved in the Turkish military offensive in northern Syria. The criteria for listing includes (among others) Turkish government officials and agencies and persons operating in targeted sectors of the Turkish economy determined by the Secretary of the Treasury to be contributing to various destabilizing activities or human rights abuses in relation to Syria.
The current notice does not create any newly sanctioned parties, but implements Executive Order 13894 and provides the criteria for the Secretary of Treasury, in consultation with the Secretary of State, to make these designations. Sanctions include blocked property and other related financial sanctions.
OFAC’s Syria-Related Sanctions page includes additional information on the new rule, including information previously published regarding Executive Order 13894 (October 14, 2019). Executive Order 13894 was used to briefly add the Turkish Ministry of National Defence, the Turkish Ministry of Energy and Natural Resources, and three senior Turkish government officials to OFAC’s Specially Designated Nationals List (SDN List).
The issuance of the Syria-Related Sanctions Regulations provide a valuable reminder that sanctions programs affect transactions beyond the obvious countries of concern. Raising similar issues a few days earlier, three companies and vessels from the Marshall Islands and one company and vessel from Greece were listed under OFAC’s Venezuela-Related sanctions program. Denied party screening for all countries is a must-do to prevent serious compliance problems.