Yes. Transactions that are ordinarily incident and necessary to give effect to the activities authorized in Syria GL 22 are authorized. Additionally, Syria GL 22 authorizes U.S. financial institutions to process transfers of funds related to authorized transactions and activities. Such financial institutions may reasonably rely upon the information available to them in the ordinary course of business with regard to compliance with Syria GL 22, provided that the financial institution does not know or have reason to know that the funds transfer is not in compliance with the provisions of the GL.
In addition, foreign financial institutions do not risk exposure to U.S. secondary sanctions pursuant to the Caesar Syria Civilian Protection Act of 2019 for engaging in or facilitating transactions and activities that are otherwise authorized or exempt for U.S. persons under the Syrian Sanctions Regulations. Please see FAQ 884 for additional information.