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On February 21, 2023, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued OFAC Compliance Communique: Guidance on Authorized Transactions Related to Earthquake Relief Efforts in Syria (“Guidance”). The Guidance responds to specific questions OFAC received related to earthquake relief efforts in Syria and explains how to provide humanitarian assistance to the Syrian people in compliance with US sanctions.

The Guidance follows Syria General License 23, issued by OFAC on February 9, 2023, which authorized all transactions related to earthquake relief that would otherwise be prohibited by the Syrian Sanctions Regulations. Please see our blog post on Syria General License 23 here.

In addition, on February 27, 2023, OFAC issued a humanitarian assistance fact sheet, Supplemental Guidance for the Provision of Humanitarian Assistance.  This fact sheet supplements OFAC’s 2014 Guidance Related to the Provision of Humanitarian Assistance by Not-for-Profit Non-Governmental Organizations to address the general licenses that OFAC added or revised on December 21, 2022 to implement the UN Security Council Resolution (UNSCR) 2664.  These December 2022 general licenses provided authorizations in 4 categories: (i) the official business of the US Government, (ii) the official business of certain international organizations and entities, (iii) transactions incident to certain humanitarian activities by NGOs, and (iv) the provision of agricultural commodities, medicines and medical devices to individuals in personal, non-commercial quantities.


Paul Amberg is a partner in Baker McKenzie’s Madrid office, where he handles international trade and compliance issues. He advises multinational companies on export controls, trade sanctions, antiboycott rules, customs laws, anticorruption laws, and commercial law matters.


Lise Test is an of counsel in the Firm’s International Trade Group in Washington, DC and practices in the area of international trade regulation and compliance — with emphasis on US export control laws (Export Administration Regulations (EAR) and International Traffic in Arms Regulations (ITAR)), trade sanctions, and anti-boycott laws. Ms. Test advises clients on issues relating to product classifications, licensing, regulatory interpretations, risk assessments, enforcement actions, internal investigations and compliance audits, as well as the design, implementation, and administration of compliance programs. Ms. Test works regularly with companies across a wide range of industries, including the pharmaceutical/medical device, telecommunications, manufacturing, and technology sectors. She joined the Firm as a summer associate in 2007 and became a full-time associate in 2008. Prior to joining Baker McKenzie, Ms. Test served as a lawyer at the Danish Ministry of Defence.


Caroline Howard is an associate in the Washington, DC office where she is a member of the International Commercial Practice Group. Her practice is focused on all aspects of international trade law, particularly compliance with US export controls, trade and economic sanctions, and US foreign investment restrictions. She represents clients in national security reviews before the Committee on Foreign Investment in the United States (CFIUS). Prior to joining the Firm, Caroline worked in telecommunications law. Specifically, she handled applications for international Section 214 authorizations, which included helping clients navigate Team Telecom's specific national security review for foreign participation in the US telecommunications sector.

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