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Web Alert: EU sanctions against Syria

26 June 2013

These sanctions have been imposed in response to the humanitarian situation in Syria.  Certain measures in this will need further Council Regulations for implementation. 

Key provisions relevant to members include:

A.         Assets freezes and restrictions on financial services

  • Freezing of funds and economic resources of listed persons / entities.  Blacklisted entities include various persons and entities in banking, oil & gas, construction, media and other fields - such as the Central Bank of Syria, the Syria International Islamic Bank, the Syria Company for Oil Transport and the Syrian Petroleum Company.  As at 10 June 2013, there were 179 individuals and 54 entities listed.  The UK list for the Syrian sanctions may be found here.
  • Restrictions are also imposed in relation to financial services.  There are not the same restrictions on fund transfers to non-blacklisted Syrian persons / entities as per the EU measures against Iran.   However, many EU banks are cautious about making payments (even in Euros) to Syrian parties, or otherwise involving Syria.

B.         Other measures

  • Ban on import, purchase or transport of crude oil or petroleum products exported from Syria (or originating in Syria). 
  • Ban on the sale, supply, transfer or export to any Syrian person / entity (widely defined to include any person, entity or body worldwide owned or controlled by any such Syrian party), or for use in Syria, of key equipment or technology for the oil & gas industry.  This includes listed equipment for the exploration and production of oil and natural gas, oil refining and the liquefaction of natural gas, including geophysical survey equipment, drilling and production units, LNG carriers, heat exchangers and certain pumps and pipes.  The ban again extends to related financial and technical assistance. 
  • Ban on the sale, supply, transfer or export of equipment or technology to be used in the construction or installation in Syria of new electricity power plants.  This consists of steam & gas turbines, electric motors and generators exceeding specified outputs.   
  • Import and export bans on arms and equipment which might be used for internal repression (including telecommunications monitoring equipment).   
  • Ban on the sale, supply, transfer or export to Syria of listed luxury goods
  • Ban on trading in gold, silver, other precious metals and diamonds with (e.g.) Syrian public bodies and their agents.  This ban applies both to sales (and supply, transfer or export) and purchases (and import or transport).  There is also a ban on the sale, supply, transfer or export of Syrian denominated banknotes and coinage to the Central Bank of Syria.
  • Ships transporting cargo to Syria must provide prior information on goods brought into or out of a member state.  Such cargo is also to be inspected where member states have reasonable grounds to believe it contains restricted items.  Prohibited goods are to be seized by member states.

Please also note:

v  There is a prohibition against knowingly and intentionally participating in activities the object or effect of which is to circumvent the aforementioned measures.

v  There is a general defence where someone did not know, and had no reasonable cause to suspect, that their actions would infringe these prohibitions.