OFAC Issues Additional Syria and Libya Sanctions General Licenses

On September 9, 2011, the Treasury Department's Office of Foreign Assets Control (OFAC) issued several general licenses relating to the U.S. sanctions programs on Syria and Libya. The following is an overview of these general licenses:

Libya General License

In the biggest change involving the current round of sanctions imposed by Executive Order 13566 on Libya on February 25, 2011, OFAC issued General License No. 7 which authorizes U.S. persons and companies to engage in transactions involving the following 16 subsidiaries of the Libyan National Oil Corporation located in Libya, Germany, Netherlands and other countries without having to obtain a specific license from OFAC:

• Arabian Gulf Oil Company
• Azzawiya Oil Refining Company
• Brega Petroleum Marketing Company
• Harouge Oil Operations
• Jamahiriya Oil Well Fluids and Equipment
• Libya Oil
• Mediterranean Oil Services Company
• Mediterranean Oil Services GmbH
• National Oil Fields and Terminals Catering Company
• North African Geophysical Exploration Company
• National Oil Wells Drilling and Workover Company
• Oilinvest Netherlands B.V.
• Ras Lanuf Oil and Gas Processing Company
• Sirte Oil Company for Production of Manufacturing of Oil and Gas
• Tamoil Group
• Waha Oil Company

It is important to note that General License No. 7 does not authorize transactions with the Libyan National Oil Corporation, Zueitina Oil Company or any other persons whose property and interests in property remain blocked pursuant to Executive Order 13566.

While OFAC has issued several other Libya general licenses, including General License No. 6 on August 19, 2011 that authorizes transactions with the Transitional National Council of Libya (formally known as the National Transitional Council), a large number of companies and entities in Libya remain blocked.

A summary of Executive Order 13566 and the current sanctions on Libya can be found here.

Because of the fast moving events in Libya U.S. persons and companies should proceed with caution before engaging in any business or financial transactions with Libya.

Syria General Licenses

OFAC issued the following four narrowly tailored general licenses with respect to the U.S. sanctions imposed on Syria on August 17, 2011 under Executive Order 13582:

General License 7​ - Authorizes transactions until November 25, 2011 that are incident and necessary to wind down contracts involving the Government of Syria. Also authorizes the divestiture to foreign persons of a U.S. person's investments in Syria.

General License 8 ​ - Authorizes U.S. persons to engage in transactions and activities in Syria associated with the United Nations and related programs and funds, including the World Health Organization, IMF, UNICEF, etc. Note 1 to the General License contains a reminder on the need to comply with other U.S. legal requirements, such as the Export Administration Regulations.
​​
General License 9 - Authorizes U.S. persons residing in Syria ​to pay to the Government of Syria personal expenses, such as housing, utilities, goods and services, taxes and fees.

General License 10​ - Authorizes U.S. financial institutions to operate accounts for non-blocked individuals in Syria as long as the transactions are for non-commercial purposes and do not involve transfers to Syria or for the benefit of persons residing in Syria.

A summary of Executive Order 13582 and the current sanctions on Syria can be found here.