Syrian Sanctions Relief and Exceptions
Summary
The Department of the Treasury's Office of Foreign Assets Control (OFAC) is publishing a general license (GL) issued pursuant to multiple regulations, including the Syrian Sanctions Regulations: GL 25. This GL was previously made available on OFAC's website.
Compliance Requirements
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All transactions prohibited by the Syrian Sanctions Regulations, 31 CFR part 542 (SySR), other than transactions involving blocked persons, are authorized.; All transactions that are prohibited by the SySR, the Weapons of Mass Destruction Proliferators Sanctions Regulations, 31 CFR part 544, the Iranian Financial Sanctions Regulations, 31 CFR part 561, the Global Terrorism Sanctions Regulations, 31 CFR part 594, the Foreign Terrorist Organizations Sanctions Regulations, 31 CFR part 597, or Executive Order 13574 involving the Government of Syria, any blocked person listed in the Annex to this general license, or any entity in which one or more of the blocked persons listed in the Annex own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest are authorized.; This general license does not authorize any transactions involving any individual or entity identified on the Office of Foreign Assets Control’s List of Specially Designated Nationals and Blocked Persons (SDN) that is not listed in the Annex of this general license, as well as any entity in which one or more of such SDNs own, directly or indirectly, individually or in the aggregate, a 50 percent or greater interest, unless separately authorized.; This general license does not authorize the unblocking of any property or interests in property blocked pursuant to any part of 31 CFR chapter V as of May 22, 2025.; This general license does not authorize any transactions for or on behalf of the Government of the Russian Federation, the Government of Iran, the Government of the Democratic People’s Republic of Korea (DPRK), or related to the transfer or provision of goods, technology, software, funds, financing, or services to or from Iran, Russia, or the DPRK.
Market Impacts
Authorization of certain transactions previously prohibited by the Syrian Sanctions Regulations, opening up opportunities for trade and financial transactions with Syria, except for transactions involving blocked persons not listed in the Annex of this general license.; Transactions for or on behalf of the Government of the Russian Federation, the Government of Iran, the Government of the Democratic People’s Republic of Korea (DPRK), or related to the transfer or provision of goods, technology, software, funds, financing, or services to or from Iran, Russia, or the DPRK are not authorized.
Validated Company Impacts
BANCFIRST CORP /OK/
BancFirst operates as a commercial bank primarily serving Oklahoma markets with no disclosed international operations or transactions involving Syria, Iran, Russia, or DPRK. The rule specifically targets entities engaged in international transactions with sanctioned countries, which falls outside this regional bank's business scope. The company explicitly lists OFAC Sanctions Compliance as a regulatory risk, directly aligning with this rule's authorization of certain Syrian transactions while maintaining prohibitions on blocked persons and specific governments. This indicates significant exposure to OFAC regulatory changes and potential financial, legal, and reputational impacts from sanctions violations.