Keller and Heckman LLP: EU Bans Exports to Syria for Oil and Gas, Electricity Production and Telecom

In response to the continued violence in Syria, today the European Union expanded its sanctions against that country by banning exports for critical sectors. The new sanctions provide a list of equipment, technology and software for the oil and gas industry and for electricity production that cannot be exported from Europe or by European entities to Syria without a license. The sanctions also identify telecommunications equipment that is subject to the same restriction because of the equipment's ability to help the Syrian regime intercept internet or telephone communications.

The types of equipment covered include:

• Oil and Gas - Survey equipment, sensors, drilling equipment, liquid/gas separators, gas compressors, subsea production equipment, pumps, tubes, heat exchangers and certain chemicals among many others;
• Electricity Production - Steam and gas turbines and electric motors and generators;
• Telecommunications - Radio frequency monitoring equipment, speaker recognition and processing equipment, network interception equipment, remote forensics equipment not otherwise already subject to EU export licensing requirements among many other types of equipment.

The new prohibitions also cover certain technical assistance and financing for the types of items subject to the export ban. The prohibitions against exports for the oil and gas sector and for electricity production, however, include a grandfathering clause for preexisting contractual obligations.

Companies that engage in business with Syria from Europe and serve the industries noted in any respect should be mindful of these new restrictions. Even if their products are not covered by the new lists, exports of those products could be restricted under the EU's general export controls. The United States also imposes very broad restrictions on business with Syria involving U.S.-origin items or services.

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