There are extensive EU and US sanctions in place in response to concerns over human rights abuses, which include asset freezes imposed on named persons/entities, trade embargoes and restrictions targeting key sectors of the economy.
It is prohibited (under EU Reg. 36/2012, Reg. 168/2012 and Reg. 1323/2014) to
- provide equipment/technology used for internal repression in Syria
- supply key equipment/ technology for the Syrian oil & gas industry
- purchase or import crude oil or petroleum products from Syria (or to provide insurance for such trades)
- supply equipment used to construct Syrian electrical power plants
- supply jet fuel or jet fuel additives (or to provide insurance for such trades)
- supply luxury goods or trade in gold/precious metals
It is prohibited (under Executive Order 13582) to:
- export or supply any services to Syria from the US or by a US person
- import Syrian-origin petroleum or petroleum products into the US
Furthermore, the property of any person in the US who has ‘materially assisted’ (i.e. provided good/services etc) to the Syrian government will be “blocked” (i.e. subject to an asset freeze).
We advise members to carefully consider the impact of sanctions should they decide to trade to Syria and strongly recommend seeking independent legal advice. Members are reminded of the need to exercise due diligence to ensure that the trade or operation is not subject to sanctions and that they do not trade with individuals or entities that are named on the EU or US sanctions lists.
The EU Consolidated sanctions list
The US sanctions list
HMT Treasury (UK)
Circulars issued by the club
18 May 2016, Standard Club Circular - Syria Sanctions
Web alerts issued by the club
New US sanctions legislation against Iran, Russia and North Korea, 09 August 2017
EU extends scope of Syria sanctions, 22 December 2014
EU sanctions against Syria, 26 June 2013
EU increase sanctions against Syria, 25 January 2012
Alerts issued by Freehill Hogan & Mahar LLP are available here