Treasury Publishes Syrian Sanctions Regulations

The Office of Foreign Assets Control (OFAC) unleashed the next salvo in the US Government’s barrage of sanctions directed against Syria when it published the entirely new Syrian Sanctions Regulations (SSR) in the Federal Register on April 5. The new regulations come nearly a year after President Bush issued his Executive Order 13338 (pdf) implementing sanctions against the Syrian regime under the Syria Accountability and Lebanese Sovereignty Restoration Act (SAA), the International Emergency Economic Powers Act (pdf) (IEEPA), and the National Emergencies Act (NEA). The new SSR draw their legal authority specifically from IEEPA, not from SAA (or, as some would more festively prefer to abbreviate it, SALSA.)

OFAC’s new regulations are in addition to last year’s rule from the Bureau of Industry and Security (BIS), which banned nearly all exports and reexports to Syria and revoked existing licenses for the country. The only exceptions to the export prohibition are for food and medicine, as well as shipments eligible under certain provisions of License Exceptions AVS, BAG, GOV, TMP, and TSU.

The new Syrian regs have more in common with those applicable to Slobodan Milosevic’s cronies, narcotics traffickers, and terrorists than the more well known Cuban or Iranian sanctions. They are intended to target specific Syrian individuals, firms or other entities that support terrorists, Syrian meddling in Iraq or Lebanon, or proliferation activity. In theory, these folks would have their property blocked. We say in theory because no one has actually been designated by OFAC under the SSR. Until Treasury takes this step, the new regulations have little practical effect.