Syria - Easing of US Sanctions - Important Notice
On January 6, 2025, OFAC issued Syria General License (“GL”) 24, authorizing various activities and transactions previously prohibited under the Syrian Sanctions regime.
These authorisations currently last six months, until 7th July 2025.
The GL allows transactions in support of the sale, supply, storage, or donation of energy, including petroleum, petroleum products and natural gas, to or within Syria provided that the products are not of Russian or Iranian origin.
There are still a number of SDN restrictions in place, so careful due diligence is still necessary and Members will need to review each potential transaction on a case-by-case basis.
For further details we refer Members to the Client Alert issued by Freehill Hogan and Mahar which can be found here.Members however need to be aware that the EU and UK regulations in relation to Syria still remain. Accordingly parties with an EU or UK nexus – which includes the Club, and hence Club cover - are still prohibited in the sale, transport, supply and delivery of aviation fuel and aviation fuel additives to Syria for use in Syria or any person in Syria. That would include products with the following HS/CN Codes:
- 2710 12 70
- 2710 19 29
- 2710 19 21
- 2710 20 90
- 3811 21
- 3811 29
- 3811 90
The UK and the EU continue to maintain restrictions by way of asset freezes on many players who are involved in the oil/petroleum products trade which means that transactions involving Syria will require careful due diligence on the transaction chain to make sure that no parties subject of any UK, US or EU asset freeze are involved.
Members therefore need to continue to exercise care in their due diligence checks to ensure that there are no breaches of the UK or EU regulations.