The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) on Friday issued four general licenses arising from its new sanctions on Syria. These are, specifically:
1. General License No. 7 (Winding Down Contracts Involving the Government of Syria; Divestiture of a U.S. Person’s Investments or Winding Down of Contracts Involving Syria). This permits the engagement by U.S. persons of wind-down activities to divest from investments in Syria related to Syria, including the export of services. All such transactions are authorized up through November 25, 2011 and those making use of this General License should submit necessary documentation to OFAC.
2. General License No. 8 (Official Activities of International Organizations). This general license allows U.S. persons working with the United Nations, its affiliates and contractors to engage in official business in Syria related to their work. Note that there are certain reporting requirements for U.S. persons.
3. General License No. 9 (Transactions Related To U.S. persons residing in Syria). This general license allows individuals to engage in normal living expenses (e.g., paying for rent, food, government taxes, etc.) in Syria.
4. General License No. 10 (Operation of Accounts). This allows individuals ordinarily resident in Syria to maintain bank accounts at U.S. financial institutions, provided that transfers are not meant to fund businesses and do not involve blocked individuals or accounts.
The text of these general licenses highlight a requirement that is arguably a central theme in most OFAC-regulated areas and transactions – record-keeping. Even when not required, best practices dictate keeping complete and accurate records relating to such transactions as they can later come under scrutiny.