Answer

The Central Bank of Syria (CBoS) is blocked as part of the Government of Syria, as defined in E.O. 13582 of August 17, 2011 and the Syrian Sanctions Regulations (SySR), 31 C.F.R. Part 542.  On December 22, 2020, OFAC identified the CBoS on the Specially Designated Nationals and Blocked Persons List (SDN List), further underscoring its blocked status.  This identification does not trigger new prohibitions on the CBoS.  All property and interests in property of the CBoS remain blocked.  

Among other things, the SySR generally prohibit U.S. persons, unless exempt or authorized, from engaging in any transaction or dealing in property and interests in property of certain blocked persons, including the CBoS.  This also includes the making of any contribution or provision of funds, goods, or services by, to, or for the benefit of any person whose property and interests in property are blocked, again including the CBoS.  The SySR also prohibit the export, reexport, sale, and supply of services to Syria (unless exempt or authorized), which would include services involving the CBoS in Syria.  

Pursuant to the Caesar Syria Civilian Protection Act of 2019, non-U.S. persons who knowingly provide significant financial, material, or technological support to, or knowingly engage in a significant transaction with the Government of Syria, including the CBoS, or certain other persons sanctioned with respect to Syria, risk exposure to sanctions. 

General and specific licenses under the SySR applicable to the CBoS continue to apply, including authorizations for the provision of humanitarian assistance and certain trade to Syria that may involve the CBoS.  For more information regarding authorizations for humanitarian assistance and other trade with Syria by U.S. and non-U.S. persons, please see FAQ 867. 

Answer

Yes.  The identification of the CBoS on the SDN List does not trigger new prohibitions; existing general and specific licenses under the Syrian Sanctions Regulations (SySR), 31 C.F.R. Part 542, continue to apply as they did previously.  U.S. persons may continue engaging with the CBoS in connection with humanitarian assistance and certain other trade with Syria authorized by the SySR or exempt from regulation, including:  § 542.510 (Exports or reexports to Syria of items licensed or otherwise authorized by the Department of Commerce authorized; exports or reexports of certain services authorized); § 542.513 (Official activities of certain international organizations authorized); § 542.516 (Certain services in support of nongovernmental organizations’ activities authorized); and § 542.525 (Exportation or reexportation of services to Syria related to the exportation or reexportation of certain non-U.S.-origin goods authorized).  Of note, the export of U.S.-origin food and most medicines to Syria is not prohibited and does not require a Commerce or OFAC license (see 31 CFR § 542.510 and Syria FAQ 229), and U.S. persons can continue engaging with the CBoS in connection with these transactions.  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.   

In addition, OFAC may issue specific licenses to authorize certain transactions involving U.S. persons or the U.S. financial system that may otherwise be prohibited by OFAC sanctions, provided those transactions are in the foreign policy interests of the United States.  OFAC has a longstanding licensing policy supporting the provision of humanitarian assistance 

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 Syria Civilian Protection Act of 2019 (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 would not risk exposure to sanctions under the Caesar Act for engaging in activity with the CBoS that is authorized for U.S. persons under a general license in the SySR, such as transactions involving the provision of humanitarian assistance or export of humanitarian goods to Syria.  Further, the Caesar Act codifies, with some exceptions, the general license in § 542.516 of the SySR that authorizes certain services in support of nongovernmental organizations, and includes a humanitarian waiver.  

OFAC remains committed to ensuring that humanitarian assistance can flow to the people of Syria.  Treasury continues to support the critical work of governments, certain international organizations, non-profit organizations, and individuals delivering food, medicine, medical supplies, and humanitarian assistance to civilians in Syria.  If individuals, companies, or financial institutions have questions about engaging in or processing transactions related to these authorizations, they can contact OFAC’s Sanctions Compliance and Evaluation Division at (800) 540-6322 or (202) 622-2490. 

Answer

As described in FAQ 867, non-U.S. persons would not risk exposure to sanctions for engaging in humanitarian-related transactions or activity with Polymedics LLC and Letia Company that are exempt from regulation or authorized for U.S. persons by a general license in the Syrian Sanctions Regulations (SySR), 31 C.F.R. Part 542, such as transactions involving the provision of humanitarian assistance or export of humanitarian goods to Syria.  

Additionally, the Caesar Syria Civilian Protection Act of 2019 (Caesar Act) codifies, with some exceptions, the general license in § 542.516 of the SySR, which authorizes certain services in support of nongovernmental organizations and includes a humanitarian waiver. 

December 22, 2020

Washington – Today, in support of the U.S. government’s efforts to promote accountability and reach a political resolution to the Syrian conflict, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctioned a high-ranking official in the Syrian government; her husband, a member of the Syrian People’s Assembly; and their business entities. Further, OFAC added the Central Bank of Syria to the Specially Designated Nationals and Blocked Persons List (SDN List), underscoring its status as a blocked person, and additionally identified the property of other previous blocked persons. In total, OFAC added two individuals, nine business entities, and the Central Bank of Syria to the SDN List, pursuant to Syria sanctions authorities. Through this action, the Department of the Treasury aims to discourage future investment in government-controlled areas of Syria, force the regime to end its atrocities against the Syrian people, and compel its commitment to the United Nations-facilitated process in line with UN Security Council Resolution 2254.

“One year ago this week, the President signed into law the Caesar Act of 2019, an important step, reaffirmed by today’s action, in holding accountable the Assad regime for the atrocities it has committed against its own people,” said Secretary Steven T. Mnuchin. “The Treasury Department will continue to use all of its tools to expose those who stand with the Assad regime and enable these crimes to continue.”

Concurrent with the Treasury Department’s designations, the State Department also designated today six Syrian persons pursuant to Section 2 of Executive Order (E.O.) 13894, “Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Syria.”

The United States will continue to stand alongside the Syrian people. Since the start of the conflict, the United States has provided over $12 billion in assistance to Syrians in need. Humanitarian organizations are reminded of OFAC’s previous guidance related to the provision of humanitarian aid. The United States continues to provide guidance, including in Treasury’s COVID-19 press release, to better inform the public, partner governments, relevant international organizations, and NGOs about the general licenses and exemptions available to ensure the provision of humanitarian aid, including to the Syrian people, remains unimpeded. In addition, with today’s action, OFAC has issued further guidance in the form of FAQs on the continued availability of humanitarian-related sanctions exceptions.

SENIOR GOVERNMENT OF SYRIA OFFICIALS

Today, OFAC designated Lina Mohammed Nazir al-Kinayeh (al-Kinayeh), the Director of the Follow-Up Office in the Office of the Syrian Presidency, a position she has held for over a decade. This office follows up on the files and decisions of the Presidential Palace’s Anti-Corruption Committee, which Assad directly supervises, using judicial, advisory, and administrative authorities under its jurisdiction. Closely aligned with the Assad regime as a high-ranking official in the Presidential Palace, al-Kinayeh has conducted a range of business and personal activities on behalf of Syrian First Lady Asma al-Assad and previously headed the Office of the First Lady of Syria. Al-Kinayeh was designated pursuant to E.O. 13573 for being a senior official of the Government of Syria.

OFAC also sanctioned Mohammed Hammam Mohammed Adnan Masouti (Masouti), al-Kinayeh’s husband, who represents the Damascus electoral district as a member of parliament in the Syrian People’s Assembly, a position to which he was first elected in 2016. Masouti is a member of the Syrian People’s Assembly’s Arab and Foreign Affairs Committee and he has also served as the Director of the Educational Hospitals Directorate in the Ministry of Higher Education, which reportedly enabled his corruption in Syria’s hospital system as well as self-serving deals with the support of his wife. Masouti’s connections to the Assad regime through his wife, as well as his businesses and vast financial holdings, make Masouti an unusually influential parliamentarian. Masouti was designated pursuant to E.O. 13573 for being a senior official of the Government of Syria.

Four companies owned or controlled by al-Kinayeh or Masouti, three as designations and one as an identification of blocked property, were added to the SDN List: Souran Company, Lia Company, Letia Company, and Polymedics LLC.

Souran Company, Lia Company, and Polymedics LLC were designated pursuant to E.O. 13573 for being owned or controlled by, or for having acted or purported to act for or on behalf of, directly or indirectly, Masouti. Letia Company was identified for being owned in the aggregate, directly or indirectly, 50 percent or more by al-Kinayeh and Masouti.

KHITI BUSINESS NETWORK

On November 9, 2020, OFAC designated Amer Taysir Khiti for being a senior official of the Government of Syria and Khiti Holding Group for being owned or controlled by, or for having acted or purported to act for or on behalf of, directly or indirectly, Amer Taysir Khiti. Today’s action added five entities to the SDN List that were identified as blocked property of Amer Taysir Khiti or Khiti Holding Group, individually or in the aggregate: Al-Amer for Manufacture of Concrete and Flagstone, Al-Amer for Manufacture of Plastic, Al-Layth Alzahabe Transportation and Shipping Services, Al-Amer Development and Real Estate Investment, and Good Land Company.

Al-Amer for Manufacture of Concrete and Flagstone and Al-Amer for Manufacture of Plastic were identified for being owned in the aggregate, directly or indirectly, 50 percent or more by Khiti Holding Group and Amer Taysir Khiti. Al-Layth Alzahabe Transportation and Shipping Services was identified for being owned, directly or indirectly, 50 percent or more by Khiti Holding Group. Al-Amer Development and Real Estate Investment and Good Land Company were identified for being owned, directly or indirectly, 50 percent or more by Amer Taysir Khiti.

CENTRAL BANK OF SYRIA

OFAC additionally added the Central Bank of Syria (CBoS) to the SDN List, highlighting its blocked status. The CBoS is already blocked as meeting the definition of the Government of Syria in E.O. 13582 and the Syrian Sanctions Regulations, 31 C.F.R. Part 542. The CBoS oversees monetary policy in Syria, and one of its main functions is the issuance of a national currency, which is exercised by the CBoS solely on behalf of the Government of Syria. The CBoS additionally regulates the operations of private sector banks and money services businesses in the markets and acts as the fiscal and depository agent of the Government of Syria. The CBoS has deep banking ties to Iran, the world’s largest state sponsor of terrorism, and the CBoS has been an integral part of the regime’s efforts to increase public revenues and prop up the Syrian currency.

SANCTIONS IMPLICATIONS

All property and interests in property of these persons that are in the United States or in the possession or control of U.S. persons must be blocked and reported to OFAC. Unless authorized by a general or specific license issued by OFAC or otherwise exempt, OFAC’s regulations generally prohibit all dealings by U.S. persons or within (or transiting) the United States that involve any property or interests in property of designated or otherwise blocked persons. In addition, non-U.S. persons that engage in certain transactions with the persons designated today may be exposed to designation.

View identifying information on the individuals and entities designated today.

For more information regarding the scope of any sanctions program’s requirements please contact OFAC’s Sanction Compliance and Evaluation Division at (800) 540-6322 or (202) 622-2490, or by email at OFAC_Feedback@treasury.gov.