Stephen M. McNabb, Marsha Z. Gerber, Stefan Reisinger and Gwen Shirl Green
August 19, 2011
President Barack Obama yesterday signed an Executive Order imposing significant new sanctions against Syria that will vastly curtail the ability of U.S. companies to conduct any business in, or provide services to, Syria or Syrian entities. Although existing U.S. export and sanctions laws already prohibited most exports of U.S.-origin goods to Syria, the new sanctions now also prohibit U.S. Persons from:
- providing, directly or indirectly, any services to Syria;
- engaging in any transactions or dealings with, or related to, Syrian-origin petroleum or petroleum products;
- importing into the United States petroleum or petroleum products of Syrian origin;
- performing new investment in Syria; and
- facilitating any transaction by a foreign person involving Syria that would be prohibited if performed by a U.S. Person.
The Executive Order also blocks all property and interests of the Government of Syria that are under the jurisdiction of the United States. Such blocked property and interests in property may not be transferred, paid, exported, withdrawn, or otherwise dealt in, by any U.S. Persons.
Finally, the U.S. Department of Treasury simultaneously added the following five Syrian petroleum-related entities to the Specially Designated Nationals List designating them as Syrian Government entities: (1) the General Petroleum Corporation; (2) Syrian Petroleum Company; (3) Syrian Company for Oil Transport; (4) the Syrian Gas Company; and (5) SYTROL.
European Union diplomats are scheduled to meet in Brussels today to discuss imposing similar severe new sanctions against Syria and its energy sector in particular. The expectation is that the new EU sanctions will be approved and go into effect as early as next week.
The new sanctions signify the strongest action the United States has taken to date to pressure the Government of Syria to end its continuing violence against the Syrian people. Companies conducting any business with Syria, Syria's petroleum industry or Syrian Government entities should analyze the effects the Executive Order may have on their activities and take appropriate steps to avoid sanctions or penalties under the law. We will continue to monitor the situation and provide additional updates as warranted.
This article was prepared by Stephen M. McNabb (email@example.com or 202 662 4528), Marsha Z. Gerber (firstname.lastname@example.org or 713 651 5296), Stefan H. Reisinger (email@example.com or 202 662 4698) and Gwen S. Green (firstname.lastname@example.org or 202 662 0437) from Fulbright's International Trade Practice Group. Stephen M. McNabb is a partner in Fulbright's Washington D.C. office and is Head of Fulbright's International Trade Practice Group. Marsha Z. Gerber is a partner in Fulbright's Houston, Texas office and is a member of the International Trade Practice Group. Stefan H. Reisinger and Gwen S. Green are attorneys in Fulbright's Washington D.C. office and members of the International Trade Practice Group.
Fulbright's International Trade Practice Group
Fulbright's International Trade Practice Group is comprised of experienced attorneys in several of Fulbright's offices throughout the world. Attorneys in the group assist clients in matters concerning international trade laws and regulations; including economic sanctions regulations, export/import control regulations, anti-boycott regulations, and anti-corruption laws.
Stephen M. McNabb
Marsha Z. Gerber
Gwen Shirl Green