On January 6, 2024, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License 24, which authorizes transactions with governing institutions in Syria and certain activities related to energy and personal remittances. OFAC explained it issued General License 24 in light of the collapse of Bashar al-Assad’s government and to support the Syrian people with maintaining essential services and continuity of governance functions in Syria. 

 OFAC issued the general license to authorize activities that would otherwise be prohibited pursuant to the Syrian Sanctions Regulations, the Global Terrorism Sanctions Regulations, and the Foreign Terrorist Organizations Sanctions Regulations.  By authorizing transactions with governing institutions in Syria, subject to some conditions and exceptions, even if a designated individual has a leadership role in that governing institution, the new GL helps address sanctions issues that would arise as a result of  Hay’at Tahrir al Sham (HTS), a designated foreign terrorist organization and specially designated global terrorist, taking control of the Syrian government. However, OFAC makes clear that HTS, the Government of Syria, and the Central Bank of Syria remain sanctioned persons and does not unblock any HTS, Government of Syria, Central Bank of Syria property or interest in property.  

To provide further clarity, OFAC released eight new FAQs (1205–1212) and updated an existing FAQ (227) addressing these recent changes. A detailed overview of the updates can be found on OFAC’s Recent Actions page.