The Caesar Act is a US legislation that imposes sanctions on the Syrian regime. Entities that provide support to the regime or that are associated with it directly or indirectly are targeted by the sanctions. Lebanon, which has close economic ties with Syria, is highly susceptible to the fallout from the implementation of the Caesar Act, although it is not directly targeted. According to Joel D. Rayburn, the US State Department’s Special Envoy for Syria, the Caesar Act sanctions are not directed at harming the Lebanese economy and they will not have a significant impact on legitimate economic activity in Lebanon. Local businesses, however, have to engage in due diligence and be aware of the do’s and don’ts related to the Act in order to know how to navigate safely in the murky waters of sanctions. The adage ‘knowledge is power’ has never been more true than it is now.
Need for expert advice
Lebanon will, directly and indirectly, be affected by the Caesar Act at the economic, political, military, and financial levels, according to , Managing Partner at Eptalex Aziz Torbey Law Firm. The extent of the impact will be discerned with time, he said. According to , Head of the Compliance Department at the law firm Eptalex Garzia Gasperi and Partner-Milan, the, Senior Partner at Alem & Associates, said: “Those who want to be involved in a deal in Syria or with Syrian entities or nationals have to take the Caesar Act sanctions very seriously.” Wise evaluation of planned ventures in Syria or related to Syria is a must and should be done on a case-by-case basis. Seeking expert advice is not a luxury anymore. , US Sanctions Lawyer at the US-based boutique law firm Berliner Corcoran & Rowe, said: “I do not want to come across as an alarmist but it is a complicated matter and you need to hire lawyers.” According to Mulazzi, there is now a strong need for highly specialized professionals to help investors carry out business operations in complex areas. , Partner at Smayra Law Office said: “Pay attention to two keywords stated in the Caesar Act ‘significant’ and ‘knowingly’. The Act does not define deals that are considered ‘significant’ this is left for judicial interpretation.” According to Hoghooghi, under other US sanctions programs, ‘significant’ transactions are determined on the basis of the totality of facts and circumstances in each case considering factors such as size, number, frequency, and nature of transactions. Other factors to be considered include the impact of transactions on statutory objectives and whether they are part of a pattern of conduct or involve deceptive practices.
