More Changes: Permitting More Aircraft Parts to be Exported to Syria

Earlier this week we reported that the government was reducing the OFAC sanctions on Syria. At that time, we warned that the BIS sanctions programs remained in place.

The government is expected to reduce the BIS sanctions against Syria next week (probably Tuesday). This is expected to include an expansion of the license exceptions that are available for shipping goods to Syria. The license exception changes are expected to include an expansion of AVS (which is currently not applicable to Syria) that will allow AVS to be used for EAR99 goods and for goods only restricted under anti-terrorism restrictions (which will include aircraft parts controlled under ECCN 9A991.d, but will exclude things like IRUs).

The RPL license exception is also expected to become available for certain transactions with Syria (e.g. for repairing aircraft or their parts for Syrian airlines), provided that such exports will not support the Syrian police, military, or intelligence sensitive end users or uses.

There will still be restrictions on exports to Syria, so be sure to check compliance requirements carefully.

These changes are expected to be immediately effective upon publication.

UPDATE: The new rule was published September 2 and was consistent with our predictions