On Aug. 4 2023, the Charity & Security Network (C&SN) sent a letter to the honorable Brian Nelson, under secretary for terrorism and financial intelligence at the U.S. Department of Treasury, urging the Office of Foreign Assets Control (OFAC) to extend General License 23 (GL 23), a sanctions exception that authorized earthquake relief activity in Syria for the last six months.
C&SN conducted extensive outreach and engagement with fellow civil society actors, United States government officials, academics, and financial institutions surrounding extending the license, the Syria humanitarian crises, and policy towards Syria. The letter was in large part informed by this engagement. GL 23 was set to expire on Aug. 8 2023. Unfortunately, the license was not extended, and Treasury instead underscored existing sanction exceptions for non-governmental organizations (NGOs) and other activity in Syria.
In the letter, C&SN highlighted three key reasons for extension, including:
- Multilateral congruency between the U.S., E.U., U.K., and Switzerland in post-earthquake licenses provides clarity and reassurances to all actors globally facilitating financial transactions for earthquake relief in Syria.
- Financial assurances to banks and financial institutions have positively impacted NGOs’ ability to transfer funds and make transactions related to humanitarian aid and earthquake relief.
- The longstanding nature of the rebuilding and humanitarian efforts needed after the earthquake requires longer than a six-month window.
Likewise, C&SN presented four recommendations surrounding GL 23 and the OFAC licensing process. These entailed:
- Extend Syria GL 23 indefinitely, in alignment with many other U.S. GLs; if deemed not politically viable, then extend for an additional six months or longer.
- Provide legally binding assurances on Syria-related licensing communication products so the financial sector will continue transferring funds and conducting transactions for activities that are already permitted under existing Syria authorizations.
- Integrate the applicable language in Syria GL 23 across the new and amended Dec. 2022 baseline GLs to create harmonization and uniformity, and to reduce the complex legal web that banks and financial institutions have to navigate to support NGO activity. This would position the U.S. as even more of a global leader in supporting banks to uphold the Financial Action Task Force’s (FATF) clear calls to implement a risk-based approach.
- Adopt a Standing General License that can be administered within the first 24-hours in the wake of a disaster of this magnitude, across global contexts. C&SN stands ready to support the development of such a license.
Read the full letter here.