Syria Update: Significant New Sanctions Imposed

On August 18, 2011, based on the “continuing escalation of violence against the people of Syria,” President Barack Obama issued Executive Order 13582 (“EO 13582”) to expand significantly U.S. sanctions on Syria. This briefing summarizes those sanctions as well as the General Licenses issued—first on August 18 and again on September 9—by the U.S. government to authorize limited transactions with Syria.

The United States has maintained a comprehensive export embargo and targeted economic sanctions against Syria since May 2004, when President George W. Bush issued Executive Order 13338 to implement the Syria Accountability and Lebanese Sovereignty Act of 2003. The export embargo has primarily been enforced by the U.S. Commerce Department, Bureau of Industry and Security (“BIS”), which administers controls on most exports of U.S. commercial goods, software, and technology. (The U.S. State Department has long administered a comprehensive arms embargo on Syria.)

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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