The Office of Foreign Assets Control (“OFAC”) today continued its cage match with Rami Makhluf, the maternal cousin of Syria’s President Bashar al-Assad and owner of Syriatel, Syria’s largest mobile phone provider. Previously, OFAC has designated Makhluf as an SDN based on the novel (and dubious) theory that Makhluf’s leveraging of his family relationship to al-Assad to obtain improper business advantages for himself in Syria threatens the security of the United States.

Today OFAC designated two of Makhluf’s most visible business enterprises as SDNs — Syriatel and Ramak Duty Free, a chain of duty free stores that includes Damascus Duty Free at the Damascus International Airport. As a result of that designation, U.S. citizens are prohibited from doing business with either entity. (OFAC’s press release on the designation can be found here.)

This may catch many Americans traveling to Syria unaware. The Damascus Duty Free at the airport is reputed to have a large selection of goods at attractive discounts and is popular among travelers departing the airport. The State Department’s guidance page on travel to Syria has not yet been updated to reflect this new restriction, stating only that, because Syria is a designated state sponsor of terrorism, U.S. citizens “are prohibited from engaging in financial transactions which a U.S. person knows or has reasonable cause to believe pose a risk of furthering terrorists’ acts in the United States.”

Americans traveling in Syria with unlocked GSM phones might also violate the sanctions if they bought a pre-paid SIM card from Syriatel for use in Syria. Buying telcom services from Syriatel is arguably exempt under the Berman Amendment, but the purchase of the hardware — the SIM card — arguably could overstep the line.

One major American company is currently providing service to Syriatel. Network Solutions is the registrar for syriatel.com, which, as of this posting, was still functioning. Given the increased penalties for violating U.S. sanctions laws, it won’t be surprising if that website disappears shortly.

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