Archive for the ‘Syria’ Category

Treasury Lists Countries Requiring Cooperation With an International Boycott

Tuesday, January 3rd, 2012 by Holly Thorne

The Department of the Treasury published a current list of countries which require or may require participation in, or cooperation with, an international boycott (within the meaning of section 999(b)(3) of the Internal Revenue Code of 1986).  The purpose of this list is to provide guidance regarding compliance with the antiboycott compliance aspects of the US tax code.  While this advice is not technically specific to the antiboycott provisions in Part 760 of the Export Administration Regulations (EAR), it certainly is a reasonable basis for a company to use when it decides how to allocate its compliance resources for compliance with the EAR antiboycott rules.

Treasury identified the following countries that “require or may require participation in, or cooperation with, an international boycott (within the meaning of section 999(b)(3) of the Internal Revenue Code of 1986),” e.g., the Arab boycott of Israel:

- Kuwait

- Lebanon

- Libya

- Qatar

- Saudi Arabia

- Syria

- United Arab Emirates

- Yemen

Iraq is not included in this list, but its status with respect to future lists remains under review by the Department of the Treasury.

Treasury Lists – Countries Requiring Cooperation with an International Boycott

Wednesday, October 5th, 2011 by Holly Thorne

The Department of the Treasury has published a current list of countries which require or may require participation in, or cooperation with, an international boycott (within the meaning of section 999(b)(3) of the Internal Revenue Code of 1986).

The countries are:

  • Kuwait
  • Lebanon
  • Libya
  • Qatar
  • Saudi Arabia
  • Syria
  • United Arab Emirates
  • Yemen

Republic of Iraq is not included in this list, but its status with respect to future lists remains under review by the Department of the Treasury.

While this list officially applies to the Internal Revenue Service (IRS) antiboycott rules, it is a reasonable indicator of the high risk countries for the EAR antiboycott regulations.

President Obama Signs Executive Order Imposing Additional Sanctions on Syria

Wednesday, October 5th, 2011 by Holly Thorne

On August 18, 2011, President Obama made a statement calling for Syrian President Bashar-Al Assad to “step aside” in light of recent events in Syria. The President also signed an Executive Order imposing the following additional sanctions on the country:

  • Requires the immediate blocking of all assets of the Government of Syria subject to U.S. jurisdiction.
  • Prohibits U.S. persons from exporting or reexporting services to Syria.
  • Prohibits U.S. imports of Syrian-origin petroleum or petroleum products
  • Prohibits U.S. persons from having any dealings in or related to Syrian-origin petroleum or petroleum products.
  • Prohibits U.S. persons, wherever located, from operating or investing in Syria.
  • Prohibits U.S. persons from approving, financing, facilitating or guaranteeing transactions by foreign person where the transaction by that foreign person would be prohibited if performed by a U.S. person or within the U.S.

Due to the Syria Accountability and Lebanese Sovereignty Restoration Act of 2003 (SAA), most exports and reexports of U.S. origin products to Syria have been prohibited since May 2004; however, the export of humanitarian products to Syria, such as medicines, agricultural products and medical devices, are still permitted with the proper licenses.

The following Syrian energy companies have been also added to the Specially Designated Nationals (SDN) List. All property of these companies subject to U.S. jurisdiction must be blocked and U.S. persons cannot engage in any transactions with these parties:

  • The General Petroleum Corporation
  • Syrian Petroleum Company
  • Syrian Company for Oil Transport
  • Syrian Gas Company
  • SYTROL: Syria’s

Additional information

Treasury Identifies Countries Participating in the Secondary and Tertiary Arab League Boycotts of Israel

Monday, June 27th, 2011 by Anna Barone

By: Anna Barone

In accordance with section 999(a)(3) of the Internal Revenue Code of 1986, the Department of the Treasury is publishing the following list of countries which require or may require participation in, or cooperation with, an international boycott:

Kuwait, Lebanon, Libya, Qatar, Saudi Arabia, Syria, United Arab Emirates, and Yemen (more…)

US BIS Extends “Temporary” Denial on Orion Air

Wednesday, November 24th, 2010 by Danielle McClellan

On May 7, 2009 an Order Temporarily Denying Export Privileges for Orion Air, S.L. and Syrian Pearl Airlines was signed for 180 days and then was renewed on November 2, 2009 and has once again been renewed for an additional 180 days.

BIS signed the initial order after they had warned Orion Air that reexporting a BAE 146-600 aircraft to Syria to the Syrian Pearl Airlines would require a license. Orion assured the US Bureau of Industry and Security (BIS) that they would put the reexport on hold based on the US Government’s concerns. Despite telling BIS that the transaction was on hold Orion Air continued with the export of the BAE aircraft to Syrian Pearl Airlines in Syria—not necessarily a good idea. When BIS uncovered the illegal reexport the initial denial order was signed based on the fact that BIS argued that future violations are likely to happen based on the fact that Orion Air lied about reexporting the aircraft to Syria and they are likely to continue to do so about other reexports. (more…)

Stop Using License Exception TSR Now!: You Need to Get a New TSR Written Assurance

Tuesday, September 7th, 2010 by John Black

BIS Expands Controls on Foreign-Made Products and Changes TSR Written Assurance

In the July 30, 2010, Federal Register the Bureau of Industry and Security (BIS) published a revision to the Export Administration Regulations (EAR) that does two things.  First, it changes the requirements for what has to be in the written assurance for exports and reexports under License Exception TSR.  Second, it changes the destination countries for which the EAR asserts jurisdiction for foreign-made direct products of US technical data or software. (more…)

Treasury Announces Countries Enforcing Boycott on Israel

Friday, October 30th, 2009 by John Black

The Department of Treasury released a list of countries that “may require participation in, or cooperation with, an international boycott (meaning of section 999(b)(3) of the Internal Revenue Code of 1986).” The following countries have been named on the list: (more…)

Foreign Subsidiaries Cause Violations for US Parent

Wednesday, September 30th, 2009 by Danielle McClellan

Most US companies spend time and money to make sure their facilities are in compliance with US export regulations but many fail to spend time educating their foreign subsidiaries on these same laws. Thermon Manufacturing Company, a Texas based firm, is a great example of this. Earlier this month Thermon voluntarily disclosed several violations and agreed to pay $176,000 in combined civil penalties. Thermon itself did not violate the EAR, but its five foreign subsidiaries did when they reexported the US company’s EAR 99 heat tracing equipment to Iran, Syria, Libya, and listed entities in India. (more…)

DHL Fined $9.44 Million for Role in Exports and Not Keeping Records

Monday, August 31st, 2009 by Danielle McClellan

Most people understand that the exporter of a good is usually the person who is responsible for export compliance; the exporter determines if the good needs a license and ensures that all records pertaining to the export are kept according to EAR requirements. Recently BIS and OFAC have proven, through civil penalties, that the exporter of the goods is not the only one responsible for export compliance, especially record keeping requirements. (more…)

Updated List of Countries Not Cooperating Fully with US Antiterrorism Efforts

Monday, May 18th, 2009 by Danielle McClellan

The Department of State has recently published the countries that are not cooperating fully with the US antiterrorism efforts. These countries are Cuba, Eritrea, Iran, Democratic People’s Republic of Korea (North Korea), Syria, and Venezuela.

Whatever you do, please do not confuse this list of “countries not cooperating fully with US antiterrorism efforts” with the list of terrorism supporting countries.

More information: