Update and Overview of Syria Sanctions

Overview

Council Regulation (EU) No 36/2012 provides a comprehensive regulation overview of the various goods, services and activities in respect of Syria which are currently subject to sanctions. 

Issued on 18 January 2012, a PDF of the regulation is attached here.  An outline of the key items and activities where compliance with EU sanctions is required is set out in the section “Update on sanctioned goods, services and activities as at 18th January 2012” below.

The regulation includes an annex (Annex II ) that lists the people, organizations and entities to which the sanctions relate.  These lists are updated frequently and so Members are recommended to regularly check for new people or entities added to the list.

There are some exemptions relating to pre-existing contracts and humanitarian uses of such items and activities. We recommend Members refer to the original regulation to clarify whether they may find themselves in potential breach of these sanctions.

A list of reference websites for competent authorities in individual EU states, as well as a contact address for communication with the European Commission is provided in Annex III.

Under Rule 5V the Club does not cover any claims arising from breach of such sanctions by a Member, or which would place the Club inbreach of sanctions were it to provide cover, or indemnify such claims.

Members should refer to any queries on cover or status relating to this Regulation, or any other sanctions, to their usual Club contact.

Update on sanctioned goods, services and  activities as at 18th January 2012

The following update lists the main groups of goods services & activities specified in this Council Regulation together with the relevant articles and annexes that describe them in detail.  Members are recommended to read the relevant original text to understand the breadth of goods and activities that are encompassed by these descriptions.

Goods and other items
• Goods which may be used in internal repression (Article 2)
• "Military List" items. (Article 3)
• Equipment used in interception and monitoring of telecommunications (Article 4 & Annex V)
• Equipment used in manufacture of Article 4 equipment (Article 5 & Annex V)
• Oil and petroleum products (Article 6 & Annex IV )
• Equipment used in the exploration, extraction or production of oil & petroleum products (Article 8 & Annex VI)
• Banknotes & coinage (Article 11)
• Infrastructure project equipment relates to power plants (Article 12 & Annex VII )

Financial
• Finance of infrastructure projects for power plants or petroleum products (Article 13)
• Freezing of financial assets (Article 14)
• Provision of banking services (Article 25)
• Provision of insurance and re-insurance (Article 26)

Exemptions
These exemptions are limited and conditional upon either special circumstances or explicit permission by relevant national authorities.  Members should read the relevant articles carefully and seek advice regarding compliance:

• Pre-existing contracts (Articles 7 & 10)
• Insurance services (Articles 26.2 & 26.3)