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Syrian Sanctions Eased to Allow More Transactions Concerning Publications

Monday, April 13, 2015
Sandler, Travis & Rosenberg Trade Report

The Treasury Department’s Office of Foreign Assets Control has issued a final rule that, effective April 13, amends the Syrian Sanctions Regulations to issue a new general license authorizing certain transactions not already exempt from regulation that support the publishing and marketing of manuscripts, books, journals and newspapers in paper and electronic format.

Authorized Transactions

- commissioning and making advance payments for identifiable written publications not yet in existence, to the extent consistent with industry practice

- collaborating on the creation and enhancement of written publications

- augmenting written publications through the addition of items such as photographs, artwork, translation, explanatory text and, for a written publication in electronic format, the addition of embedded software necessary for reading, browsing, navigating or searching the written publication

- exporting embedded software necessary for reading, browsing, navigating or searching a written publication in electronic format, provided that the software is designated as EAR99 or is not subject to the Export Administration Regulations

- substantive editing of written publications

- payment of royalties for written publications

- creating or undertaking a marketing campaign to promote a written publication

- other transactions necessary and ordinarily incident to the publishing and marketing of written publications

However, this license will not apply if the parties to such transactions include the government of Syria (excluding any academic or research institutions and their personnel) or any other person whose property and interests in property are blocked.

Unauthorized Transactions

This rule does not authorize U.S. persons to do the following.

- provide or, if involving blocked property, receive individualized or customized services (including accounting, legal, design or consulting services) other than those necessary and ordinarily incident to the publishing and marketing of written publications, even though such services are delivered through the use of information or informational materials

- create or undertake for any person a marketing campaign with respect to any service or product other than a written publication or create or undertake a marketing campaign of any kind for the benefit of the government of Syria

- engage in the exportation or, if involving blocked property, the importation of goods to or from Syria other than the exportation of embedded software described above

- operate a publishing house, sales outlet or other office in Syria

This rule also does not authorize the following.

- the exportation from or, if involving blocked property, the importation into the U.S. of services for the development, production or design of software

- transactions for the development, production, design or marketing of technology specifically controlled by the International Traffic in Arms Regulations, the EAR or the Department of Energy regulations set forth at 10 CFR part 810

- the exportation of information or technology subject to the authorization requirements of 10 CFR part 810, restricted data as defined in section 11 y. of the Atomic Energy Act of 1954, or other information, data or technology the release of which is controlled under the Atomic Energy Act and its regulations

- the exportation of any item (including information) subject to the EAR where a U.S. person knows or has reason to know that the item will be used, directly or indirectly, with respect to certain nuclear, missile, chemical or biological weapons or nuclear-maritime end-uses

- the exportation of information subject to licensing requirements under the ITAR or exchanges of information that are subject to regulation by other government agencies

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