New U.S. Sanctions against Syria

On the 18^th August 2011, the US Government issued an Executive Order that blocks property of the Syrian government, including all entities controlled by the Syrian government. The Executive Order prohibits exportation, sale or supply of services from the United States to Syria. Imports into the United States of Syrian-origin petroleum and petroleum products are also prohibited. Under the Executive Order U.S persons* are forbidden to:

• undertake new investment in Syria;

• export, re-export, sell or supply services to Syria from any location;

• engage in dealings in or related to Syrian-origin petroleum or petroleum products; or

• approve, finance, facilitate or guarantee any transaction by a foreign person if U.S. persons are prohibited to participate in such a transaction. 

In addition, the U.S. Government has blocked property of the following Syrian petroleum companies:

• General Petroleum Corporation: The state-owned company that controls Syria's oil and gas industry and is responsible for the exploration, development and investment of Syria's oil and gas exploration activities.

• Syrian Petroleum Company: An entity that is responsible for upstream oil production and development in Syria.

• Syrian Company for Oil Transport:  An entity that manages Syria's domestic pipeline system and is responsible for transporting all Syrian crude and petroleum products. Syrian Company for Oil Transport manages Syria's three major oil export/import terminals: Baniyas, Tartous and Latakia.

• Syrian Gas Company:  An entity that is responsible for processing, transporting and marketing Syria's natural gas.

• SYTROL: Syria's state oil marketing firm, which is responsible for selling Syrian crude to foreign buyers.

These entities join previously blocked Syrian individuals and entities on the Treasury Department's Office of Foreign Assets Control List of Specially Designated Nationals.

*The measures define "U.S. person" to include any citizen or resident of the United States, any entity organized under U.S. law, and any individual or entity in the United States.

The UK Club is grateful to Mr Melvin Schwechter of Dewey & LeBoeuf LLP for providing the information on Syrian sanctions. If Members would like more information they can contact Mr Schwechter via email or their usual Club contact.