response to the escalating violence in Syria, President Obama issued today an
Executive Order imposing broad new sanctions that could significantly disrupt
business that was permissible under preexisting U.S. sanctions. This action
follows a U.N. Security Council condemnation of the violence and less
restrictive European Union sanctions. The new U.S. sanctions, which are
effective immediately, will likely have the greatest effect on U.S. companies
that provide services relating to Syria, invest in Syria or are closely
involved with their non-U.S. affiliates' business with Syria.
following summarizes the activities the new sanctions prohibit:
prior U.S. sanctions against Syria had prohibited exports and reexports by
anyone of most goods and technologies that were of U.S. origin or
were produced outside the United States with more than de minimis
U.S. content. Those sanctions also prohibited dealings in certain property and
property interests of several members of the Syrian government. The new
sanctions significantly expand those prohibitions.
interpretative issues are likely to arise in connection with the new Syrian
sanctions. For example, companies will likely have difficulty in determining
whether a U.S. company involved with non-U.S. companies making sales to Syria
might also be providing services to Syria. In addition, the scope of the prohibition
on new investment is uncertain. New regulations will likely be promulgated to
provide further details on the scope of these sanctions. In the meantime, U.S.
companies will need to proceed with additional caution should their business
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