Article by: Glenn Shearron, Trade Compliance, TradeInsights, ECoP

While recent developments from the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) have significantly altered the landscape of U.S. sanctions on Syria, exporters should be aware that the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) continues to maintain strict licensing requirements for shipments to Syria under the Export Administration Regulations (EAR).

While President Trump issued EO 14312 terminating the U.S. compressive sanctions program targeting Syria, BIS export controls remain in full effect. Currently, BIS continues to require a license for all exports or reexports and transfers (in-country) to Syria, other than food and medicine designated as EAR99, as described in Section 746.9 of the EAR. There is a general policy of denial for exports and reexports to Syria of items subject to the EAR.

BIS has signaled it is in the process of drafting a rule that would ease export licensing for certain non-sensitive and humanitarian items destined for Syria. While this rule is reportedly under interagency review, no regulatory changes have been finalized or published, and exporters should not assume any change in licensing requirements until an official rule is issued in the Federal Register.

Key Takeaways:

• BIS continues to require export licenses for nearly all shipments to Syria.
• OFAC sanctions relief does not impact BIS export licensing obligations.
• BIS has not eased any licensing requirements.
• Exporters should monitor the Federal Register and BIS updates closely.

We will continue to monitor developments and provide updates as they become available.

Please contact your V. Alexander account team, or you may also contact our Trade Compliance team at tradeinsights@valexander.com with any questions, and you can always follow us on our website www.valexander.com for updates on this and other topics.