UPDATE: September 21, 2023
August 8 saw the expiration of OFAC’s General License 23, but providing humanitarian relief in Syria is still allowed under Section 542.516 of the existing sanctions regime. Known as the “Syria NGO General License,” it permits funding for relief of basic human needs, albeit with higher due diligence requirements for financial institutions which had been waived under GL23., Depending on their capacity, some financial institutions may see delays in vetting payments to Syria–or, as noted by the Charity and Security Network, elect to not facilitate them at all.
OFAC has published detailed, updated guidance on humanitarian assistance to Syria here. Syria is still recovering from the quake, and more than 11,000 aftershocks have been detected by Turkiye’s Interior Ministry. Please see CAF America’s list of Turkiye/Syria earthquake resources on our response page.
Yesterday, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) released a new General License (NO. 23) authorizing “all transactions related to earthquake relief efforts in Syria that would otherwise be prohibited by the Syrian Sanctions Regulations (SySR).” This is welcome news for funders and responders, and CAF America is pleased to see OFAC recognizing the importance of allowing access to financial aid.
What Are General Licenses?
General Licenses are sweeping authorizations for activities that would be otherwise sanctioned under US law. General Licenses are issued by OFAC from time to time, and once issued they can be used by anyone to substantiate the decision to proceed with otherwise prohibited activities. When an activity is authorized by General License, no application or special permission is needed from OFAC before actions can happen. See more on how General Licenses effect grantmaking in this whitepaper, co-published with CAF America and the Charity & Security Network.
What Is Not Authorized
These General Licenses, like many others, do not authorize transactions with blocked persons on the Specially-Designated Nationals (SDN) list. Syria has a high concentration of SDNs, and other anti-terror and war-related sanctions remain in place. Any funder giving to Syria must ensure that their grants meet the other high standards in place.
Who You Can Support
While this authorization is a positive step for opening up financial support and grants, anyone looking to support those affected in Syria must take into account the substantial physical barriers to aid. CAF America has already approved the following organizations active within Syria for grants advised by our donors (note that none of these organizations are registered in Syria itself):
- Fondazione Avsi
- Dar Al-Ajaza Al-Islamia Association
- People In Need
- INJAZ AL-Arab
- Islamic Relief Canada
- Associazione Pro Terra Sancta
- Tkiyet Um Ali Society for Charitable and Voluntary Works
- International Rescue Committee, Inc.
- United States Fund For Unicef
- United Kingdom for UNHCR
- Polish Center for International Aid Foundation
- Mercy Corps
- International Medical Corps
Are you a CAF America Fund Holder?
Consider supporting any of the vetted charities we are partnering with for relief efforts, or making a donation to CAF America’s Türkiye & Syria Earthquake Relief Fund, which will fund local relief efforts across the region. Recommend a grant for earthquake relief using this template form.
Other Resources
PODCAST: New OFAC General Licenses for Humanitarian Relief: What Grantmakers Need to Know
NEWS ALERT: CAF America Welcomes New OFAC General Licenses for Humanitarian Aid
U.S. TREASURY DEPARTMENT: Addition of General Licenses for the Official Business of the United States Government and Certain International Organizations and Entities and Updates to the 50 Percent Rule Interpretive in OFAC Sanctions Regulations
U.S. TREASURY DEPARTMENT: Publication of Humanitarian-related Regulatory Amendments and Associated Frequently Asked Questions
