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May 2, 2011

Syrian Sanctions Issued During Obama's Big Weekend

Lost in the news coverage of the release of President Obama's long form birth certificate, the
Royal Wedding, and the assassination of Osama Bin Laden, was the issuance of a new round of
sanctions against Syria. On Friday, April 29, 2011, President Obama signed into effect
an executive order which has blocked certain individuals and entities in Syria from the U.S.
financial system.

As is the case with sanctions, all those targeted by the sanctions who have assets held in the
United States have had those assets blocked. In addition, there are prohibitions installed which
bar U.S. persons from providing funds, goods, or services, to those parties designated under the
sanctions. U.S. persons are also prohibited from receiving funds, goods, or services from anyone
blocked pursuant to this new set of sanctions against Syria. In addition, the President indicated in
his executive order that humanitarian donations, generally permitted under the International
Emergency Economic Powers Act (IEEPA), are not prohibited to any of the targeted parties.

Those parties who were designated by the President for sanctions include:

1. Mahir AL-Asad, the Brigade Commander in the Syrian Army’s Fourth Armored Division;
2. Ali Mamluk, the Director of the Syrian General Intelligence Directorate;
3. Atif Najib, the former head of the Syrian Political Security Directorate for Dar’a Province
4. Syrian General Intelligence Directorate
5. Islamic Revolutionary Guard Corps – Qods Force

Within the last few months we have seen the President quickly turn to sanctions to target those
parties involved in suppressing political dissension in both Libya and Syria. The speed at which
these sanctions are being imposed may very well show that Obama is serious about addressing
the political oppression taking place in those countries, however, I have to imagine that it is
having a tremendous strain upon the agency which administers and enforces these sanctions: The
United States Department of the Treasury Office of Foreign Assets Control (OFAC). OFAC
already has limited resources and from discussions I have had with a number of officials has
been very busy implementing the Libya sanctions program. Now with a new round of sanctions
aimed at Syria, OFAC will certainly be faced with a massive backlog as they struggle to
maintain not only their former workload--which was significant--but also the new workload
created by the implementation of two new rounds of sanctions over the last three months. I sense
a whole host of delays coming up, particularly in relation to licensing.
The author of this article is Erich Ferrari, an attorney specializing in OFAC matters. If you have
any questions please contact him at 202-280-6370 or ferrari@ferrari-legal.com.