On February 22, 2012, the Office of Foreign Assets Control
(OFAC) issued
General License No. 15 for the Syria sanctions President Obama
implemented in August.
President Obama's
Executive Order No. 13582 blocked property of the Syrian
government and prohibited certain transactions with respect to
Syria, expanding on executive orders and sanctions that were
previously issued by the Bush II Administration. The Bush
Administration sanctions primarily applied to exports or reexports
of U.S. origin goods or goods containing more than a de
minimis U.S. content. The current Administration's
sanctions apply to a much wider scope of goods and services.
To date, however, the Administration has not implemented any
regulations relating to the Syrian sanctions, so U.S. persons have
been unsure as to how broadly the new sanctions would apply.
Therefore, most exporters have taken a conservative stance and
presumed they cannot transact any business with Syria, directly
