U.S. Department of the Treasury

Syria GL 22 authorizes certain activities in non-regime held areas of northeast and northwest Syria in the following economic sectors:  agriculture; information and telecommunications; power grid infrastructure; construction; finance; clean energy; transportation and warehousing; water and waste management; health services; education; manufacturing; and trade.  This includes activities in the areas of northeast and northwest Syria identified in the Annex in Syria GL 22, in support of transactions and activities that fall within the categories listed above, including:

• the provision of agricultural-related services (such as the production of agricultural inputs, agricultural processing facilities, and the distribution of equipment and spare parts for machinery used in crop and livestock production); 
• the provision of information and telecommunications-related services (such as reestablishment of telecommunications infrastructure, the promotion of internet connectivity for the Syrian people, and support for media and journalists);
• the provision of power grid infrastructure and clean energy-related services (such as rehabilitation of distribution grids and lines, transformers or substations; and maintenance of power stations); 
• activities to support construction-related services (such as repairs to residential buildings; rehabilitation of health facilities, schools, bakeries, irrigation pumps, and canals; and supplying associated spare parts, training, and support for maintenance of equipment);
• the provision of financial-related services in support of the sectors outlined in Syria GL 22 (such as the provision of grants and loans, and entry into contracts to support private capital investments and trade);
• the provision of transportation and warehousing-related services (such as rehabilitation of roads, bridges, waterways, and pipelines; and supplying associated technologies for alternative energy for transportation);
• the provision of water and waste management-related services (such as rehabilitation of solid waste and medical disposal sites; and treatment of sewage and irrigation systems); 
• the provision of healthcare and health-related services (such as the distribution of medical equipment, supplies, and pharmaceuticals; and technical training for and supervision of healthcare workers); 
• the provision of educational-related services (such as the rehabilitation of schools; the provision of training and equipment support to local educators; training and equipment support to local officials on the operations and management of critical infrastructure; the provision of vocational and business management training; and the preservation and protection of cultural heritage sites); and
• activities to support trade, including manufacturing of civilian-use goods directly benefiting the people in non-regime held areas of northeast and northwest Syria.

Additionally, Syria GL 22 authorizes U.S. financial institutions to process transfers of funds in support of the authorized transactions and activities outlined above.  

Separately, non-U.S. persons, including 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 SySR.  Please see FAQ 884 for additional information. 

Please note that this guidance does not apply to transactions and activities that may be subject to prohibitions under other sanctions programs administered by OFAC (e.g., transactions with persons blocked under OFAC’s counterterrorism authority (E.O. 13224, as amended) or OFAC’s Syria-related authority (E.O. 13894)), unless exempt or otherwise authorized by OFAC.  Any persons seeking to operate in non-regime held areas of northeast and northwest Syria must ensure their in-country activities do not involve prohibited transactions and activities or blocked persons, such as the Government of Syria or designated terrorist organizations.

For transactions and activities not otherwise authorized or exempt from sanctions, OFAC will consider license requests on a case-by-case basis.  Individuals, companies, or financial institutions with questions about engaging in or processing transactions related to this authorization can contact OFAC’s Sanctions Compliance and Evaluation Division most efficiently via email at OFAC_Feedback@treasury.gov.  Sanctions Compliance and Evaluation may also be reached via phone at (800) 540-6322 or (202) 622-2490.

Additionally, U.S. and non-U.S. persons may need to obtain a license from the Department of Commerce’s Bureau of Industry and Security (BIS) for the export or reexport or certain items subject to Export Administration Regulations (EAR).  For further guidance regarding the exportation or reexportation of items to Syria, please contact BIS at (202) 482-4252.

For the purposes of Syria GL 22, the Annex in GL 22 identifies areas of northeast and northwest Syria in which activities described in GL 22 are authorized as of May 12, 2022.

Syria GL 22 does not authorize activities involving persons blocked pursuant to the Syrian Sanctions Regulations, 31 C.F.R. part 542, including the Government of Syria, or persons that may be subject to sanctions under other sanctions programs administered by OFAC (e.g., transactions with blocked persons designated under Executive Order (E.O.) 13224, as amended (OFAC’s counterterrorism authority), or E.O. 13894 (OFAC’s Syria-related authority)), unless exempt or otherwise authorized by OFAC.

Persons conducting activities in certain non-regime held areas in northeast and northwest Syria pursuant to Syria GL 22 can use OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List) Search Tool to identify organizations and individuals explicitly included on the SDN List, as well as other individuals or entities explicitly subject to U.S. sanctions.  For more information on using OFAC’s SDN List Search Tool and assessing OFAC Name Matches, please see OFAC FAQs 5, 82, 246-253, 287, 369, 467, and 892. 

In addition, according to OFAC’s 50 Percent Rule entities are considered blocked if they are owned 50 percent or more, directly or indirectly, individually or in the aggregate, by one or more blocked persons. 

OFAC would encourage any persons operating in certain non-regime held areas of northeast and northwest Syria pursuant to Syria GL 22 to use all information at their disposal when assessing their risk for sanctions exposure.  Supplementing internal due diligence information with an array of open-source material can be an effective compliance practice to aid in identifying risky counterparties involved in any in-country activity.  For more information on OFAC due diligence expectations and compliance programs, please see FAQs 25, 27-31 and A Framework for OFAC Compliance Commitments.
 

No.  Syria GL 22 does not remove any sanctions on the Assad regime and excludes transactions involving any person, including the Government of Syria, whose property or interests in property are blocked pursuant to the Syrian Sanctions Regulations or the Caesar Syria Civilian Protection Act of 2019 from the scope of the authorization.  Additional information on activities authorized pursuant to Syria GL 22 can be found in FAQ 1043.

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.
 

Syria GL 22 is intended to improve the economic conditions in non-regime held areas of northeast and northwest Syria and support ongoing stabilization efforts in the region.  This new authorization also builds upon the Administration’s strategy to defeat ISIS in the region. 

The GL at § 542.516 of the SySR authorizes NGOs to engage in activities in support of certain not-for-profit activities in Syria, including:  humanitarian projects that meet basic human needs; democracy-building; education; non-commercial development projects directly benefitting the Syrian people; and the preservation and protection of cultural heritage sites.  This includes early-recovery-related transactions and activities by NGOs in support of transactions and activities that fall within the categories listed above, including:

• the provision of healthcare and health-related services (such as the restoration of health facilities; the distribution of medical equipment, supplies, and pharmaceuticals; and technical training for and supervision of healthcare workers); 
• the provision of educational support and training services (such as the rehabilitation of local schools, the provision of training and equipment support to local educators, training and equipment support to local officials on the operations and management of critical infrastructure, and the provision of vocational and business management training); 
• the provision of agricultural-related services (such as the refurbishment of mills, silos, and bakeries to improve food security; the provision of veterinary health services and pharmaceuticals to promote the health of livestock; and training and distribution of agricultural related items); and
• activities related to shelter and settlement assistance, and clean water assistance (such as the rehabilitation and restoration of conflict-damaged water systems, sanitation, and hygiene infrastructure; supplying associated spare parts, training, and support for maintenance of equipment; and rehabilitation of irrigation pumps and canals). 

For transactions and activities not otherwise authorized or exempt from sanctions, OFAC considers license requests on a case-by-case basis.  Individuals, NGOs, companies, or financial institutions with questions about engaging in or processing transactions or activities related to this authorization can contact OFAC’s Sanctions Compliance and Evaluation Division most efficiently via email at OFAC_Feedback@treasury.gov. Sanctions Compliance and Evaluation may also be reached via phone at (800) 540-6322 or (202) 622-2490. 

The GL at § 542.516 of the SySR continues to authorize, subject to certain limitations, NGOs to engage in certain transactions and activities that would otherwise be prohibited in support of the following not-for-profit activities in Syria:

• Humanitarian projects that meet basic human needs;
• Democracy-building;
• Education;
• Non-commercial development projects directly benefitting the Syrian people; and
• The preservation and protection of cultural heritage sites.

The transactions and activities that NGOs are authorized to engage in include:

• Transactions with persons who meet the definition of the term Government of Syria, as defined in § 542.305(a) (i.e., the state and the Government of the Syrian Arab Republic, as well as any political subdivision, agency, or instrumentality thereof, including the Central Bank of Syria), that would otherwise be prohibited by § 542.201(a)(1); 
• New investment (i.e., a transaction that constitutes a commitment or contribution of funds or other assets, or a loan or other extension of credit) in Syria that would otherwise be prohibited by § 542.206;
• Exportation or reexportation of services that would otherwise be prohibited by § 542.207; and
• Purchase of refined petroleum products of Syrian origin for use in Syria that would otherwise be prohibited by § 542.209.

Early-recovery-related transactions and activities that fall within the categories of transactions and activities listed above are authorized.  For transactions and activities not otherwise authorized or exempt from sanctions, OFAC considers license requests on a case-by-case basis.

Additionally, this GL authorizes U.S. financial institutions to process transfers of funds in support of the authorized transactions and activities outlined above.

Separately, non-U.S. persons, including NGOs and 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 SySR.  Please see FAQ 884 for additional information.

Please note that this guidance does not apply to transactions and activities that may be subject to sanctions under other sanctions programs administered by OFAC (e.g., transactions with persons blocked under OFAC’s counterterrorism authority (E.O. 13224, as amended) or OFAC’s Syria-related authority (E.O. 13894)), unless exempt or otherwise authorized by OFAC.

Yes.  The Syrian Sanctions Regulations (SySR) § 542.513 authorize, subject to certain conditions, the United Nations, its Specialized Agencies, Programmes, Funds, and Related Organizations and their employees, contractors, or grantees to engage in all transactions and activities in support of their official business in Syria, including any stabilization and early recovery-related activities and transactions in support of their official business.  This authorization applies to all employees, grantees, and contractors carrying out the official business of the United Nations, its Specialized Agencies, Programmes, Funds, and Related Organizations, including nongovernmental organizations (NGOs) and private sector entities that are acting as grantees or contractors.  Please be aware that grantees or contractors conducting activities and transactions authorized under § 542.513 must provide a copy of their contract or grant with the United Nations, or its specialized Agencies, Programmes, Funds, and Related Organizations to any U.S. person, including U.S. financial institutions processing funds transfers in support of the authorized activities, before the U.S. person engages in or facilitates any transaction or activity.

In addition, § 542.211(d) and the general license at § 542.522 exempt and authorize, respectively, subject to certain conditions, the Federal Government and its employees, grantees, or contractors to engage in all transactions in support of their official business in Syria, including any stabilization and early recovery-related activities and transactions in support of their official business.  This exemption and authorization apply to all employees, grantees, and contractors carrying out the official business of the Federal Government, including NGOs and private sector entities that are acting as grantees or contractors.  Please be aware that grantees or contractors conducting transactions authorized under § 542.522 must provide a copy of their grant or contract with the Federal Government to any U.S. person, including U.S. financial institutions processing funds transfers in support of the authorized activities, before the U.S. person engages in or facilitates any transaction.  

For NGOs that are not acting as grantees or contractors of the aforementioned international organizations or the Federal Government, please see § 542.516 for authorizations under the SySR related to the export or reexport of certain services to Syria in support of certain NGO activities.

Separately, non-U.S. persons, including NGOs, private sector entities, and foreign financial institutions facilitating or assisting in the aforementioned activities, do not risk exposure to U.S. secondary sanctions pursuant to the Caesar Syria Civilian Protection Act of 2019 for engaging in the above activities that are authorized or exempt for U.S. persons under the SySR.  Please see FAQ 884 for additional information.

Please note that this guidance does not apply to transactions and activities that may be subject to sanctions under other sanctions programs administered by OFAC (e.g., transactions with persons blocked under OFAC’s counterterrorism authority (E.O. 13224, as amended) or OFAC’s Syria-related authority (E.O. 13894)), unless exempt or otherwise authorized by OFAC.
 

Yes.  The export of U.S.-origin food and most medicines to Syria is not prohibited and does not require a Department of Commerce Bureau of Industry and Security (BIS) or OFAC license (see 31 CFR § 542.510, 15 CFR § 746.9, and Syria FAQ 229), and therefore non-U.S. persons would not risk exposure to sanctions under the Caesar Syria Civilian Protection Act of 2019 (Caesar Act) for engaging in such activity.  See FAQ 884.  For questions specific to transactions involving items subject to the Export Administration Regulations destined to Syria, please contact the BIS Foreign Policy Division at Foreign.Policy@bis.doc.gov.  Additionally, U.S. persons providing services ordinarily incident to the export or reexport of certain non-U.S.-origin food and most medicines to Syria is not prohibited and does not require an OFAC specific license (see 31 CFR § 542.525), and therefore non-U.S. persons would not risk exposure to sanctions under the Caesar Act for engaging in such activity.  For more information on the most relevant exemptions, exceptions, and authorizations for humanitarian assistance and trade under the Syria sanctions program, please see OFAC’s April 16, 2020 Fact Sheet: Provision of Humanitarian Assistance and Trade to Combat COVID-19.

OFAC remains committed to ensuring that humanitarian assistance can flow to the people of Syria and maintains a favorable policy supporting the provision of humanitarian assistance.  Treasury continues to support the critical work of governments, certain international organizations, NGOs, and individuals delivering food, medicine, medical supplies, and humanitarian assistance to civilians in Syria.  In an effort to ensure assistance reaches those in need, we encourage individuals, companies, or financial institutions who have questions about engaging in or processing transactions related to these authorizations, to contact OFAC’s Sanctions Compliance and Evaluation Division at (800) 540-6322 or (202) 622-2490.

With respect to non-U.S. persons, OFAC will not consider transactions to be “significant” for the purpose of a sanctions determination under the Caesar Act if U.S. persons would not require a specific license from OFAC to participate in such a transaction.  Accordingly, non-U.S. persons, including NGOs and foreign financial institutions, would not risk exposure to sanctions under the Caesar Act for engaging in activity, or facilitating transactions and payments for such activity, that is authorized for U.S. persons under a general license (GL) issued pursuant to the SySR.

For a list of GLs within the SySR related to humanitarian assistance and trade with Syria, please see OFAC’s April 16, 2020 Fact Sheet: Provision of Humanitarian Assistance and Trade to Combat COVID-19.  Further, Section 7425 of the Caesar Act codifies, with some exceptions, the general license in § 542.516 of the SySR that authorizes certain services in support of NGOs.  Additionally, Section 7432 of the Caesar Act includes a humanitarian waiver for activities not otherwise covered by GL § 542.516 of the SySR.

Furthermore, non-U.S. persons do not risk exposure to sanctions pursuant to the Caesar Act for engaging in or facilitating transactions and activities authorized pursuant to Syria GL 22, or transactions that are ordinarily incident and necessary to give effect to the activities authorized in Syria GL 22, or any other general license issued pursuant to the SySR.

Please note that this guidance with respect to non-U.S. persons does not apply to transactions and activities that may be subject to sanctions under other sanctions programs administered by OFAC (e.g., transactions with blocked persons designated under Executive Order (E.O.) 13224, as amended (OFAC’s counterterrorism authority) or E.O. 13894 (OFAC’s Syria-related authority)), unless exempt or otherwise permitted by OFAC.

Updated: May 12, 2022