Syria

Information as of: 21st June 2017 

Latest Updates

 UN S/Res/2332 (2016) renewed authorisation for use of certain routes across conflict lines for UN Humanitarian Agencies until 10 Jan 2018.
 US Syrian Air Force, Army and Navy Jan 2017 added to SDN List.
 EU/UK Council Decision (CFSP) 2017/917 renewed EU restrictive measures against the Syrian regime until 1 June 2018.

 

                                                                                                                                                                                                             

Financial/Other Sanctions

UN S/Res/1636 (2005)
US EO 13572. EO 13582. EO 13573.
EU/UK 2011/273/CFSP. Updated 2013/255/CFSP (2013). Updated July 2013 (EU) 697/2013. Council Reg (EU) 1332/2013 & EU 124/2014 (Feb 2014) allows competent authorities to authorise certain payments.

 

                                                                                                                                                                                                             

Arms Embargo

UN No
US No
EU/UK 2011/273/CFSP. Updated 2013/255/CFSP (2013).

 

                                                                                                                                                                                                             

Further Details

UN S/Res/1636 (Oct 2005) imposed travel restrictions & financial assets freeze on any individual suspected of involvement in assassination of the former PM of Lebanon (see Lebanon above). S/Res/2118 effective 27 Sep 2013 requires Member States to prohibit the procurement of chemical weapons, related equipment, goods and technology or assistance from the Syrian Arab Republic by their nationals, or using their flagged vessels or aircraft, whether or not originating in the territory of the Syrian Arab Republic. S/Res/2165 (14 Jul 2014) and S/Res/2258 (22 Dec 2015) authorises use of certain routes across conflict lines for UN Humanitarian Agencies, renewed by S/Res/2332 (2016) until 10 Jan 2018.
US May 2004, economic sanctions enacted, including ban on exports to Syria, prohibition on flights & freezing of assets of designated entities. Apr 2011 (EO 13572) introduced assets freeze on individuals connected with human rights abuses. Aug 2011, EO13582 & EO 13573 imposed block on Syrian Government assets / property - some exceptions granted in Sep 2011. Prohibits export, sale or supply of services from U.S. to Syria & imports into U.S. of Syrian-origin petroleum products. U.S. Persons also prohibited from making new investments in Syria, selling or supplying services to Syrian entities or 'approving, financing, facilitating or guaranteeing' any transaction by a non-U.S. person where U.S. persons would be prohibited from engaging in such activity. A number of Syrian companies have also had their property / assets blocked, including General Petroleum Company, Syrian Petroleum Company, Syrian Company for Oil Transport, Syrian Gas Company & SYTROL. EO 13606 (Apr 2012) blocks property & imposes travel ban on individuals suspected of human rights abuses via information technology. EO 13608 (May 2012) prevents access to US financial / commercial systems for non-US entities deemed to have violated sanctions. Aug 2012, the 'Iran Threat Reduction & Syria Human Rights Act of 2012', which allows for a variety of further measures relating to censorship & human rights abuses.  Designated entities updated periodically. 15 Mar 2013 General Licence 16 issued allowing certain financial services to the National Coalition of Syrian Revolutionary & Opposition Forces. Jun 2013 licence policy issued in respect of telecommunications & agricultural sectors of Syria & in respect of petroleum or petroleum products of Syria origin for the benefit of National Coalition of Syrian Revolutionary & Opposition Forces or its supporters. 13 Apr 2015 General Licence issued for certain activities related to publishing. SDN list periodically updated, recently Cham Wings Airlines (Dec 2016) and Syrian Air Force, Army and Navy (Jan 2017) added.
EU/UK

EU / UK: May 2011, Arms embargo, assets freeze & travel restrictions (2011/273/CFSP). Reg 442/2011 (May 2011, entered into force 3 Sep 2011) banned sale, supply, transfer or export of goods along with related technical assistance, brokering services, financing or financial assistance to a Syrian party or for use in Syria; ban on making economic resources available to designated Syrian parties whose assets are frozen. Sep 2011, EU Reg 950/2011 prohibited trade in Syrian currency & provision of financial services to designated entities. Sep 2011, Reg 878/2011 outlined prohibition on purchase, import or transportation from Syria of crude oil & petroleum products (specifically includes (re)insurance transactions).  Exceptions allowed the execution of pre-existing contract obligations, provided that execution took place on or before 15 Nov 2011 & that the competent Member State authority was notified in advance. Dec 2011, sanctions extensively updated (2011/782/CFSP).  Consolidated all measures into new regulation – Reg 36/2012 (Jan 2012) - which repeals & replaces Reg 442/2011. Article 26(1)(a) of Reg 36/2012 specifically prohibits provision of (re)insurance to State of Syria or its Government. Article 26 prohibits extension or renewal of (re)insurance agreements concluded before 19 Jan 2012 except for prior contractual obligations to accept an extension or renewal of a policy. Exceptions relating to compulsory classes of insurance, personal lines & chartered vessels or aircraft. Further designations added via Reg 168/2012 (Feb 2012) & Reg 266/2012 (Mar 2012) & include Central Bank of Syria & prohibitions on transport of certain aviation cargoes, gold & other precious metals. EU measures updated by 2012/206/CFSP (Apr 2012), introduces additional ban / controls on export of certain goods which might be used for internal repression & luxury goods & ban on provision of certain services. Jun 2012, Reg 545/2012 added further entities to designated list (including Syria International Islamic Bank). Reg 545/2012 also clarifies provisions in Reg 36/2012 relating to the prohibition of insurance related to the sale, supply or transport of military technology. Reg 867/2012 (24 Sep 2012) slightly modifies several articles in Reg 36/2012, in particular in respect of the permission of certain transfers of funds or economic resources to & from the Central Bank of Syria in respect of trade contracts. Further designations added in Nov 2012 (Regs 944/2012 & 1117/2012). 2013/186/CFSP (May 2013) extends sanctions to include embargo on key equipment, technology & provision of services to the oil & natural gas industry, restrictions on the provision of (re)insurance & prohibition to satisfy claims made by persons & entities listed. Extended to 1 Jun 2015 by Council Decision 2014/309/CFSP. EU Reg 697/2013 (July 2013) allows competent authorities in EU Member States to authorise certain prohibited transactions under certain circumstances, including the import, purchase or transport of Syrian Crude oil or petroleum products, export of key equipment for the oil & gas sector or the provision of financing (including (re)insurance) in connection with these activities & the restrictions on certain types of military & internal repression equipment are now at the discretion of Member States. In addition certain products used for internal repression that were excluded have been amended so as to allow items identified as consumer goods packaged for retail sale for personal use, with the exception of isopropanol. EU Reg 1332/2013 (Dec 2013) allows competent authorities to authorise certain payments in respect of food, shelter, sanitation or hygiene for civilian use. EU Reg 124/2014 (effective 12 Feb 2014) licences funds for Organisation for the Prohibition of Chemical Weapons. Council Regulation EU 2015/1828 effective 12 Oct 2015 expands the criteria for inclusion in the EU's sanction regime against Syria.  7 Dec 2016 2016/2137 amends EU 36/2012 to ensure effective delivery of humanitarian aid and civilian assistance. Council Decision (CFSP) 2017/917 renewed EU restrictive measures against the Syrian regime until 1 June 2018. SDN list updated periodically.

 

This information has been collated by the International Underwriting Association of London and is intended as a guide only. The IUA does not accept any liability for the accuracy of this information.
This publication is intended to convey only general information about sanctions legislation and associated insurance coverage. It is not, and is not intended to be, a complete statement of the law relating to this area. It should not be relied on or be used as a substitute for legal advice in relation to any particular set of circumstances. Accordingly, IUA does not accept any liability for any loss which may arise from reliance on this information.