OFAC designated Emma Tel LLC ("Emma Tel"), a telecommunications provider, along with twelve other entities and two individuals, to the Specially Designated Nationals and Blocked Persons List ("SDN List"). The designations were in response to efforts by the identified entities to assist the regime of Bashar al-Assad.
In a General License, OFAC authorized certain "wind down and divestment transactions," which otherwise would be prohibited by the Syrian Sanctions Regulations, related to Emma Tel, through December 30, 2020. OFAC specified that the General License does not authorize (i) the unblocking of any property that is blocked in pursuance to OFAC regulations or (ii) activities with blocked entities or persons other than Emma Tel and its majority-owned subsidiaries.
In a related FAQ, OFAC clarified that the General License authorizes wind-down transactions with Emma Tel or any of its majority-owned subsidiaries, provided that such transactions are not in violation of the Caesar Syria Civilian Protection Act of 2019 and are consistent with the General License. OFAC also noted that wind-down transactions that involve non-U.S. persons are permitted to be processed through the U.S. financial system. OFAC encouraged non-U.S. persons who are unable to wind down transactions in accordance with the General License to seek guidance from OFAC.
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