Broad new Syria sanctions

On 18 August 2011, President Obama issued an Executive Order expanding substantially the U.S. sanctions against Syria, effective immediately. Specifically, the new measures include a requirement for "U.S. persons" to block (freeze) the property and property interests of the Government of Syria (and any entities owned/controlled by it), and impose new restrictions on a wider range of transactions with or involving Syria. Previously, the U.S. government maintained a broad ban on exports and reexports to Syria of commodities, software, and technology subject to U.S. law, as well as more limited sanctions that targeted only persons and entities named as Specially Designated Nationals (SDN) of Syria. Until yesterday, the entire Government of Syria was not subject to sanctions, and the provision of a wide range of services to Syria generally was permissible unless an SDN was involved. The new Executive Order broadens the Syria restrictions and essentially imposes a comprehensive embargo, which will have a significant impact on the ability of U.S. companies to engage in transactions involving Syria.

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