- ' 't : 'oMEN- _ ' "'RE/ . ASHiNc . . )220 LICENSE No. SY-2012-294747-1 SYRIAN SANCTIONS REGULATIONS LICENSE fGranted underthe authority of 50 U,S,C. ?? 1701 etseq., 50 U.S,C, ?? 1601 etseq., 22 U.S.C. ? 287c, Executive Orders 13338, 13399, 13460, 13572, 13573, 13582, and 13606, and 31 C.F,R. Parts 501 and 542,) TO: Syrian Support Group, Inc. c/o: Asbahi Law Group Ltd. 1050 Connecticut Ave., NW, lO"" Floor Washington, DC 20036 Attn.: Mazen Asbahi Esq. 1. Based on the correspondence dated May 24, 2012, to the Office of Foreign Assets Control (the "Application"), the transactions and activities delineated herein are hereby authorized. 2. This License is granted upon the statements and representations made in the Application, or otherwise filed with or made to the Treasury Department as a supplement to the Application, and is subject to the condition, among others, that the Licensee comply in all respects with all regulations, rulings, orders and instructions issued by the Secretary of the Treasury under the authority of the International Emergency Economic Powers Act (50 U.S.C. ?? 1701 et .seq.), the National Emergencies Act (50 U.S.C. ?? 1601 et seq.), section 5 ofthe United Nations Participation Act of 1945, as amended (22 U.S.C. ? 287c), and the terms ofthis License. 3. The Licensee shall furnish and make available for inspection any relevant information, records, or reports requested by the Secretary ofthe Treasury, or any other duly authorized officer or agency. 4. This License expires on July 31, 2014, is not transferable, and is subject to the provisions of Executive Orders 13338, 13399, 13460, 13572, 13573, 13582, and 13606, and 31 C.F.R. Parts 501 and 542, and any regulations and rulings issued pursuant thereto. This License may be revoked or modified at any time at the discretion ofthe Secretary of the Treasury. If this License was issued as a result of willful misrepresentation, it may, at the discretion of the Secretary of the Treasury, be declared void from the date of its issuance or from any other date. 5. This License does not excuse compliance with any law or regulation (including reporting requirements) administered by the Office of Foreign Assets Control or another agency applicable to the transaction(s) herein licensed, nor does it release the Licensee or third parties from civil or criminal liability for violation of any law or regulation. Issued on behalf of the Secretary of the Treasury: OFFICE OF FCtflEIGN ASSETS CONTROL LJy 'v, >> J i,/, Andrea Gacki Assistant Director for Licensing t)ate Attention is directed to 18 U.S,C, ? 1001, 22 U.S,C, ? 287c(b), 50 U,S.C, ? 1705, and 31 C.F,R, Part 542.701 for provisions relating to penalties. LICENSE No. SY-2012-294747-1 Page 2 of 2 SECTION I - AUTHORIZATION: Subject to the terms and conditions set forth in this License, the Syrian Support Group, Inc. (the "Licensee") may export, reexport, sell, or supply to the Free Syrian Army ("FSA") financial, commumcations, logistical, and other services otherwise prohibited by Executive Order 13582 in order to support the FSA, as described in the Application. SECTION I I - CONDITIONS: Any transfer of funds through the U.S. financial system pursuant to the authorization set forth in SECTION I hereof should reference the number of this License to avoid the blocking or rejection ofthe transfer. SECTION I I I - WARNINGS: (a) Nothing in this License authorizes the transfer of any funds, securities, services, or other value to the Government of Syria, which includes its agencies, instrumentalities, and controlled entities, or any other person whose property and interests in property are blocked pursuant to Executive Orders 13338, 13399, 13460, 13572, 13573, 13582, or 13606. (b) Except as expressly authorized in SECTION I hereof, nothing in this License authorizes transactions prohibited by 31 C.F.R. chapter V, or by any other laws or regulations administered by the Office of Foreign Assets Control. (c) The authorization set forth in this License applies only to laws and regulations administered by the Office of Foreign Assets Control, and should not be interpreted to excuse the Licensee from compliance with other laws, regulations, orders, or rulings to which it may be subject. In particular, please note that the U.S. Department of Commerce, Bureau of Industry and Security, administers restrictions on the exportation and reexportation of certain items to Syria. SECTION IV - RECORDKEEPING AND REPORTING REQUIREMENTS: (a) The Licensee is subject to the recordkeeping and reporting requirements of, inter alia, 31 C.F.R. ?? 501.601 and 501.602, including the requirement to maintain full and accurate records concerning the transactions undertaken pursuant to this License for a period of five years. Such records shall clearly demonstrate the applicability of the authorization set forth in SECTION I hereof (b) The Licensee must file a detailed report of transactions undertaken pursuant to this License, including but not limited to the parties involved, the value of the transactions, the services provided, and the dates of the transactions, with the Office of Terrorism Finance and Economic Sanctions Policy at the U.S. Department of State, 2201 C Street, NW, Washington, DC 20520, ATTN: Syria Desk, beginning August 31, 2012, and on the last day of each month thereafter. The report should reference Case No. SY-2012294747-1. In the event no transactions occur during a month, this should also be reported. SECTION V - PRECEDENTIAL EFFECT: The authorization contained in this License is limited to the facts and circumstances specific to the Application. -k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-h-kii-^-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k-k^