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Restrictions & Sanctions

European Union Regulations on Syria

European Union (EU) sanctions currently in force against Syria include (but are not limited to):

  • Arms embargo (incl. equipment, goods and technology which might be used for internal repression)
  • Ban on the import of crude oil and petroleum products
  • Ban on jet fuels and additives
  • Ban on equipment and technology for the oil and natural gas industry
  • Ban on luxury goods
  • Financial restrictions
  • Restrictions on provision of insurance and re-insurance
  • Travel ban

Arms embargo
Council Decision 2013/255/CFSP of 31 May 2013 provides for an embargo on arms and related materiel (Art. 3) and an embargo on certain equipment, goods and technology which might be used for internal repression (Art. 1 & 2).

Further exemptions are provided under Council Regulation (EU) No. 697/2013 of 22 July 2013 (Art. 1) and Council Decision 2013/760/CFSP of 13 December 2013 (Art.1).

Ban on the import of crude oil and petroleum products
Council Decision 2013/255/CFSP of 31 May 2013 provides for a ban on the purchase, import or transport from Syria of crude oil and petroleum products, including related services such as direct or indirect financing or financial assistance, insurance and reinsurance (Art. 5), with certain exemptions (Art. 6). Further exemptions are provided under Council Regulation (EU) No. 697/2013 of 22 July 2013 (Art. 1 (6)).

Ban on jet fuels and additives
Council Regulation (EU) No. 1323/2014 of 12 December 2014 introduced a ban on jet fuels and additives being sold, supplied, transferred or exported, whether or not originating in the Union, to any person, entity or body in Syria, or for use in Syria. This ban includes direct or indirect financial assistance, insurance, reinsurance or brokering services relating to any of the aforementioned transactions.

Ban on equipment and technology for the oil and natural gas industry
Council Decision 2013/255/CFSP of 31 May 2013 provides a ban on the sale, supply or transfer of key equipment and technology for the following key sectors of the oil and natural gas industry in Syria, or to Syrian or Syrian-owned enterprises engaged in those sectors outside Syria, by nationals of Member States, or from the territories of Member States, or using vessels or aircraft under the jurisdiction of Member States shall be prohibited whether or not originating in their territories: (a) refining; (b) liquefied natural gas; (c) exploration; (d) production (Art. 8). Certain exemptions are provided under Art. 9 & 10.

Ban on luxury goods
Council Decision 2013/255/CFSP of 31 May 2013 prohibits the sale, supply, transfer or export of luxury goods to Syria (Art. 13).

Financial restrictions
Financial sanctions include the freezing of funds and economic resources of certain persons and entities (Art. 28 of Council Decision 2013/255/CFSP of 31 May 2013).

The list of persons and entities has since been amended/updated under various Decisions, Regulations, etc. and therefore members should consult the "Consolidated list of persons, groups and entities subject to EU financial sanctions" available via the link below.

Restrictions on provision of insurance and re-insurance
Council Decision 2013/255/CFSP of 31 May 2013 prohibits the provision of insurance and re-insurance to certain persons, entities and bodies, with certain exemptions. (Art. 24)

Travel restrictions 
Travel ban on persons/entities designated by the EU.

US issues guidance to address illicit shipping and sanctions evasion practices

The advisory  includes a detailed set of best practices for private industry to consider adopting to mitigate exposure to sanctions risk.

The advisory updates and expands upon previous advisories issued by the US government. It is intended to provide actors that utilize the maritime industry for trade with information on and tools to counter current and emerging trends in sanctions evasion related to shipping and associated services. The advisory highlights common deceptive shipping practices used with respect to countries like Iran, Democratic People's Republic of Korea and Syria.

 

Philippine immigration restrictions

According to the Philippine Ship Agents’ Association (PSAA) the current situation may be outlined as follows, following a meeting between the PSAA and the Bureau of Immigration:

  1. Visaed crew list requirement remain in force in line with security concerns of the recent crisis in Marawi
  2. List of restricted 13 nationals was provided per DFA Foreign Service Circular 22-10:

    • Afghanistan 
    • Algeria
    • Egypt
    • Iran
    • Iraq
    • Jordan
    • Lebanon
    • Libya
    • Pakistan
    • Palestine
    • Sudan
    • Syria
    • Yemen
    • Stateless persons
  3. It was clarified that denying entry into the country is not only confined to the island of Mindanao which is under Martial Law, per Immigration AO JHM2017 006, above nationals will also be restricted to:

    • Areas of conflict - this is where Mindanao is currently classified under being under martial law
    • Areas of international assembly - example: ASEAN, these nationals are denied entry into Manila during the ASEAN
    • Places where the President and or other key officials of government are present - example: during visit of the President and PM Abe of Japan, entry into Davao was not allowed
    • Other areas that may be identified by the commissioner or his authorized representative

    It was explained further that the AO has no time frame. Restriction will apply anytime when any of the 4 conditions is present. For the Mindanao Martial Law, this is envisaged to end on 31 December 2017. 

  4. Two points were then raised, what will be the procedure if a vessel is:

    • Ships coming from outside Philippine territory and is already steaming to Mindanao
    • Already at a port in Luzon or Visayas then bound for Mindanao.

    No definite procedure was given, however it can be that either vessel is requested to drift outside or if allowed, to anchor while waiting for the immigration approval. 

  5. If a vessel has restricted nationals on board, the initial inclination per policy is to deny entry. But in consideration of not inhibiting trade immigration may consider entry, but, the agent must:

    • make an appeal to the immigration office and explain the legitimate purpose of the vessel's call. One suggestion from the authorities is to request owners to prove that the nationals in question do not have any record. It was suggested that documents from other foreign parties may help, such as a letter from the embassy/embassies of the particular individuals certifying their identity etc.
  6. The bureau has no set implementing guidelines yet on how they will manage a vessel with restricted crew that is granted entry. It is possible that they may put additional guards and or refuse issuance of shore passes.
  7. Having a visaed crewlist or visa does not guarantee entry. According to the Bureau, the DFA can issue a visa, but the final approval for entry will still be up to the immigration's enforcement of policy. For example: The applicant may obtain visa but if the person arrives at the airport or seaport and displays a behavior that shows reasonable cause to deny entry, it will be immigration's decision to deny entry/deportation. 

 

Trading restrictions (Syria)

Trading restrictions imposed against Syria

  • Arab League
    Syria's membership was suspended in November 2011.
    Sanctions include financial sanctions against the Syrian Central Bank, the freezing of member state government project funding in Syria and freezing assets relating to the Government entities and individuals. There is also a travel ban on senior government officials.

  • Canada
    Sanctions include:
    - an asset freeze and a prohibition with dealings with certain designated entities.
    - a prohibition on the import, purchase, acquisition, or transportation of petroleum or petroleum products, excluding natural gas, from Syria.
    - a prohibition on new investment in the oil industry in Syria and
    - a prohibition on providing financing for either of the activities described above.

  • European Union
    The sanctions provides for an arms embargo, a ban on internal repression equipment, and restrictions on the admission to the Union, and the freezing of funds and economic resources, of certain persons and entities.

    The sanctions also include a prohibition on the purchase, import or transportation from Syria of crude oil and petroleum products

  • Israel

  • Turkey
    Turkey has stated that it will follow the Arab League's sanctions against Syria.

  • USA: Syrian sanctions

  • UK sanctions on Syria

 

Trading restrictions imposed by Syria

 

Restrictions & sanctions (Syria)

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