Policy Guidance for Syrian Oil (Department of Treasury, Office of Foreign Asset Control)

Matthew Petti filed this request with the Department of Treasury, Office of Foreign Asset Control of the United States of America.
Tracking #

A-2024-00162

DOS Case: C-2021-00042

2021-FOIA-00045

Multi Request Policy Guidance for Syrian Oil
Due Jan. 12, 2021
Est. Completion July 1, 2024
Status
Awaiting Response

Communications

From: Matthew Petti


To Whom It May Concern:

Pursuant to the Freedom of Information Act, I hereby request the following records:

Any foreign policy guidance issued by the U.S. State Department to the U.S. Treasury's Office of Foreign Asset Control regarding applications to work with Syrian oil filed between October 2017 and December 2020.

In October 2017, the U.S.-backed Syrian Democratic Forces (SDF) seized control of Al-Omar in Deir al-Zour province, home to the largest oil field in Syria. (https://www.dw.com/en/us-backed-sdf-captures-syrias-largest-oil-field-from-islamic-state/a-41066879)

On December 9, 2020, U.S. Deputy Assistant Secretary of State for Levant Affairs and Special Envoy for Syria Joel Rayburn confirmed to the House Foreign Affairs Committee that a company called Delta Crescent Energy, LLC had been a given a license from the Office of Foreign Asset Control to work with oil fields under SDF control. Deputy Assistant Secretary Rayburn stated that the State Department had issued "foreign policy guidance" in support of Delta Crescent Energy, LLC's application, stating that U.S. officials "support trying to get the economy of northeast Syria up and running to the extent it can under the present conditions of war." (https://responsiblestatecraft.org/2020/12/09/trump-administration-helped-gop-donors-get-syria-oil-deal/)

Delta Crescent Energy, LLC was granted a license in April 2020, per documents released by the Office of Foreign Asset Control to investigative journalist Zack Kopplin on December 9. Three other companies had applied for a license from the Office and were rejected, according to an earlier report by Kopplin. (https://newrepublic.com/article/158841/pompeo-trump-steal-oil-kurds-syria-iraq)

I am seeking expedited processing of my request pursuant to 5 U.S.C.§ 552(a)(6)(E) because there is an urgency to inform the public concerning actual or alleged Federal Government activity in a matter of current exigency to the American public..

In response to Rayburn's remarks during the December 9 hearing, Deputy Assistant Secretary Rayburn admitted that the State Department had not discussed an oil for any other company. Congressman Joaquin Castro of Texas noted in response that Delta Crescent Energy, LLC had been co-founded by a prominent donor to Republican Party causes. "We are just leaving what has been a dark period of corruption and graft, sometimes fraud, that has been looked the other way, sometimes, I would argue, encouraged by the Trump administration," Castro said.

Therefore, the public has an urgent need to know as much as possible about Delta Crescent Energy, LLC's relationship with the U.S. Government and with U.S. Government activities in Syria, especially as U.S. troops are risking life and limb to safeguard Syrian oil fields.

President Donald Trump had stated in October and November 2019 that U.S. military forces are remain in Syria "only for the oil" and that they "may have to fight for the oil." At least two U.S. service members have died in Syria since he made these statements, and at least four were injured in an August 2020 skirmish with Russian forces (https://www.politico.com/news/2020/08/26/us-troops-injured-russian-forces-syria-402347).

Foreign countries have condemned the U.S. presence on Syrian oil fields, increasing the risk to Americans stationed there. The Turkish foreign ministry called any U.S. move to extract Syrian oil "utterly unacceptable" (https://www.hurriyetdailynews.com/turkey-slams-us-over-oil-deal-with-ypg-in-syria-157090), while the Syrian government denounced the rumored deal as "an assault against Syria’s sovereignty" and "a continuation of the U.S. hostile approach towards Syria" (http://www.sana.sy/en/?p=198923).

Additionally, federal courts have recognized the public's interest in breaking news, which "conveys information the public wants quickly,” “would lose value if it were delayed" (Am. Civil Liberties Union of N. Cal., 2006 WL 1469418 at *6.), and may have an "impact" on the public's political decision-making (Id. at *7).

Syria policy certainly could impact the public's political decision-making process. The Turkish invasion of northeastern Syria in October 2019 caused several congressional hearings and an high volume of news coverage. The public would undoubtedly have an interest in understanding further developments in U.S. policy in the same region of Syria, especially as the transition to a new presidential administration approaches in January 2021.

I am willing to pay up to $100 in fees, but I also believe that I qualify for a fee waiver as a media requester. I am an investigative journalist who has been published in the Daily Beast, the Asia Times, Responsible Statecraft, National Interest, Reason Magazine, America Magazine and the Armenian Weekly, and am requesting these documents in an editorial capacity.

The requested documents will be made available to the general public, and this request is not being made for commercial purposes.

In the event that there are fees, I would be grateful if you would inform me of the total charges in advance of fulfilling my request. I would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not.

Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response to this request within 20 business days, as the statute requires.

Sincerely,

Matthew Petti

From: Department of Treasury, Office of Foreign Asset Control

RE: Your FOIA Request to Treasury, Case Number 2021-FOIA-00237

Dear Mr. Petti :

This email acknowledges the receipt of your Freedom of Information Act (FOIA) request to the U.S. Department of the Treasury, dated 12/14/2020 . You have requested access to the following records:

“Department of Treasury, Office of Foreign Asset Control FOIA Office Department of the Treasury Washington, DC 20220 December 14, 2020 To Whom It May Concern: Pursuant to the Freedom of Information Act, I hereby request the following records: Any foreign policy guidance issued by the U.S. State Department to the U.S. Treasury's Office of Foreign Asset Control regarding applications to work with Syrian oil filed between October 2017 and December 2020.” (Date Range for Record Search: From 10/1/2017 To 12/16/2020)

Your request has been assigned to the Office of Foreign Assets Control (OFAC). OFAC will contact you directly concerning your request. Your request may require further submissions and/or justifications in order to be processed.

When inquiring about your request, please reference FOIA case number 2021-FOIA-00237 and contact the OFAC FOIA Requester Service Center at 202-622-2500, option 3 or via email at OFACFOIAOffice@treasury.gov.

Sincerely,

​​

Michelle Henshaw, Case Manager

FOIA and Transparency

Office of Privacy, Transparency, and Records

From: Department of Treasury, Office of Foreign Asset Control

Dear Mr. Petti,

RE: FOIA No. 2021-FOIA-00237
OASIS No.: 1163478

Attached is OFAC's acknowledgement of your FOIA request number 2021-FOIA-00237.

If you have any questions regarding this matter, you may email OFACFOIAOffice@treasury.gov<mailto:OFACFOIAOffice@treasury.gov> or contact the FOIA Requester Service Center at 202-622-2500, option 3. Please reference your FOIA No. 2021-FOIA-00237 in any future communications.
Regards,

OFAC FOIA Office

From: Department of Treasury, Office of Foreign Asset Control

Dear Mr. Alexander;

Re: Response to Status Update Request

OFAC is in receipt of your status update request for:

1. Any and all documents between the International Monetary & Financial Policy's ("IMF") and OFAC pertaining to the transfer of funds by HSBC Bank USA, N.A. ("HSBC") on behalf of Praxis Capital Group, LLC and/ or John C. Martinez.
2. Any and all documents pertaining to any funds blocked or otherwise frozen by OFAC, IMF, or HSBC, relating to Praxis Capital Group, LLC and/or John C. Martinez.

Please be advised that there are currently 269 FOIA requests ahead of your request in our queue. OFAC processes its request on a first-in, first-out basis. Because your request relates to financial records OFAC is required to process any responsive records through the Treasury submitter notice process found at 31 C.F.R §1.5. This places your request in our complex queue.

We are unable at this time to provide you with a date certain when we can process a response to you. We are working diligently to process our backlog and get to your request.

If you have any further questions or concerns please feel free to contact us at our FOIA Requester Service Center at 202-622-2500, option 3, or via email to OFACFOIAOffice@treasury.gov<mailto:OFACFOIAOffice@treasury.gov>. Please reference FOIA number 2021-FOIA-00045 in all communications regarding this request.

Sincerely,

Marshall Fields
Assistant Director
Information Disclosure and Records Management
Office of Sanctions Support and Operations
Office of Foreign Assets Control

OFAC FOIA Requester Service Center
OFACFOIAOffice@treasury.gov<mailto:OFACFOIAOffice@treasury.gov>
202-622-2500, Option 3

Confidentiality Notice:
This email may contain privileged, confidential and or law enforcement sensitive information which is exempt from disclosure under applicable law. If you have received this communication in error, you are hereby notified that any dissemination, distribution or copying of the communication is strictly prohibited. If you have received this communication in error, please notify the sender.

From: Department of Treasury, Office of Foreign Asset Control

Dear Mr. Anderson:

Re: FOIA No. 2021-FOIA-00045
OASIS No.: 1203338

Attached is OFAC's final response to your FOIA request.

If you have any questions regarding this matter, you may email OFACFOIAOffice@treasury.gov<mailto:OFACFOIAOffice@treasury.gov> or contact the FOIA Requester Service Center at 202-622-2500, option 3. Please reference your FOIA No. 2021-FOIA-00045 in any future communications.

Regards,

OFAC FOIA Office

Contact Information:
Information Disclosure and Records Management Division
Office of Sanctions Support and Operations
Office of Foreign Assets Control
Department of the Treasury
FOIA Requester Service Center
(202) 622-2500, option 3
F: (202) 622-1657
OFACFOIAOffice@treasury.gov<mailto:OFACFOIAOffice@treasury.gov>

Confidentiality Notice:
This email may contain privileged, confidential and or law enforcement sensitive information which is exempt from disclosure under applicable law. If you have received this communication in error, you are hereby notified that any dissemination, distribution or copying of the communication is strictly prohibited. If you have received this communication in error, please notify the sender.

From: Department of Treasury, Office of Foreign Asset Control

Dear Mr. Petti:

Re: FOIA No. 2021-FOIA-00237
OASIS No.: 1222556

Attached is OFAC's final response to your FOIA request.

If you have any questions regarding this matter, you may email OFACFOIAOffice@treasury.gov<mailto:OFACFOIAOffice@treasury.gov> or contact the FOIA Requester Service Center at 202-622-2500, option 3. Please reference your FOIA No. 2021-FOIA-00237 in any future communications.

Sincerely,

Marshall Fields
Assistant Director
Information Disclosure and Records Management
Office of Sanctions Support and Operations
Office of Foreign Assets Control

OFAC FOIA Requester Service Center
OFACFOIAOffice@treasury.gov
202-622-2500, Option 3

Confidentiality Notice:
This email may contain privileged, confidential and or law enforcement sensitive information which is exempt from disclosure under applicable law. If you have received this communication in error, you are hereby notified that any dissemination, distribution or copying of the communication is strictly prohibited. If you have received this communication in error, please notify the sender.

From: Department of Treasury, Office of Foreign Asset Control

From: requests@muckrock.com <requests@muckrock.com>
Sent: Wednesday, November 3, 2021 1:01 AM
To: OFAC FOIA Office <OFACFOIAOffice@treasury.gov>
Subject: RE: Freedom of Information Act Request #2021-FOIA-00045

** Caution: External email. Pay attention to suspicious links and attachments. Send suspicious email to suspect@treasury.gov **

Mr. Anderson:
Please find attached OFAC’s Final Response to 2021-FOIA-00045. Thank you.

Sincerely

OFAC FOIA

Department of Treasury, Office of Foreign Asset Control
FOIA Office
Department of the Treasury
Washington, DC 20220

November 3, 2021

This is a follow up to request number 2021-FOIA-00045:

To Whom It May Concern:

I wanted to follow up on the following Freedom of Information Act request, copied below, and originally submitted on Dec. 13, 2020. Please let me know when I can expect to receive a response. You had assigned it reference number #2021-FOIA-00045.

Thanks for your help, and let me know if further clarification is needed.

View request history, upload responsive documents, and report problems here:
https://hyperlink.services.treasury.gov/agency.do?origin=https://www.muckrock.com/

Filed via MuckRock.com
E-mail (Preferred): requests@muckrock.com

For mailed responses, please address (see note):
MuckRock News
DEPT MR 105775
411A Highland Ave
Somerville, MA 02144-2516

PLEASE NOTE: This request is not filed by a MuckRock staff member, but is being sent through MuckRock by the above in order to better track, share, and manage public records requests. Also note that improperly addressed (i.e., with the requester's name rather than "MuckRock News" and the department number) requests might be returned as undeliverable.

---

On Sept. 3, 2021:
Subject: FOIA No. 2021-FOIA-00237 - OFAC Final Response
Dear Mr. Petti:

Re: FOIA No. 2021-FOIA-00237
OASIS No.: 1222556

Attached is OFAC's final response to your FOIA request.

If you have any questions regarding this matter, you may email OFACFOIAOffice@treasury.gov<mailto:OFACFOIAOffice@treasury.gov> or contact the FOIA Requester Service Center at 202-622-2500, option 3. Please reference your FOIA No. 2021-FOIA-00237 in any future communications.

Sincerely,

Marshall Fields
Assistant Director
Information Disclosure and Records Management
Office of Sanctions Support and Operations
Office of Foreign Assets Control

OFAC FOIA Requester Service Center
OFACFOIAOffice@treasury.gov
202-622-2500, Option 3

Confidentiality Notice:
This email may contain privileged, confidential and or law enforcement sensitive information which is exempt from disclosure under applicable law. If you have received this communication in error, you are hereby notified that any dissemination, distribution or copying of the communication is strictly prohibited. If you have received this communication in error, please notify the sender.

---

On June 17, 2021:
Subject: FOIA No. 2021-FOIA-00045- OFAC Final Response
Dear Mr. Anderson:

Re: FOIA No. 2021-FOIA-00045
OASIS No.: 1203338

Attached is OFAC's final response to your FOIA request.

If you have any questions regarding this matter, you may email OFACFOIAOffice@treasury.gov<mailto:OFACFOIAOffice@treasury.gov> or contact the FOIA Requester Service Center at 202-622-2500, option 3. Please reference your FOIA No. 2021-FOIA-00045 in any future communications.

Regards,

OFAC FOIA Office

Contact Information:
Information Disclosure and Records Management Division
Office of Sanctions Support and Operations
Office of Foreign Assets Control
Department of the Treasury
FOIA Requester Service Center
(202) 622-2500, option 3
F: (202) 622-1657
OFACFOIAOffice@treasury.gov<mailto:OFACFOIAOffice@treasury.gov>

Confidentiality Notice:
This email may contain privileged, confidential and or law enforcement sensitive information which is exempt from disclosure under applicable law. If you have received this communication in error, you are hereby notified that any dissemination, distribution or copying of the communication is strictly prohibited. If you have received this communication in error, please notify the sender.

---

On May 13, 2021:
Subject: RE: Freedom of Information Act Request #2021-FOIA-00045
Dear Mr. Alexander;

Re: Response to Status Update Request

OFAC is in receipt of your status update request for:

1. Any and all documents between the International Monetary & Financial Policy's ("IMF") and OFAC pertaining to the transfer of funds by HSBC Bank USA, N.A. ("HSBC") on behalf of Praxis Capital Group, LLC and/ or John C. Martinez.
2. Any and all documents pertaining to any funds blocked or otherwise frozen by OFAC, IMF, or HSBC, relating to Praxis Capital Group, LLC and/or John C. Martinez.

Please be advised that there are currently 269 FOIA requests ahead of your request in our queue. OFAC processes its request on a first-in, first-out basis. Because your request relates to financial records OFAC is required to process any responsive records through the Treasury submitter notice process found at 31 C.F.R §1.5. This places your request in our complex queue.

We are unable at this time to provide you with a date certain when we can process a response to you. We are working diligently to process our backlog and get to your request.

If you have any further questions or concerns please feel free to contact us at our FOIA Requester Service Center at 202-622-2500, option 3, or via email to OFACFOIAOffice@treasury.gov<mailto:OFACFOIAOffice@treasury.gov>. Please reference FOIA number 2021-FOIA-00045 in all communications regarding this request.

Sincerely,

Marshall Fields
Assistant Director
Information Disclosure and Records Management
Office of Sanctions Support and Operations
Office of Foreign Assets Control

OFAC FOIA Requester Service Center
OFACFOIAOffice@treasury.gov<mailto:OFACFOIAOffice@treasury.gov>
202-622-2500, Option 3

Confidentiality Notice:
This email may contain privileged, confidential and or law enforcement sensitive information which is exempt from disclosure under applicable law. If you have received this communication in error, you are hereby notified that any dissemination, distribution or copying of the communication is strictly prohibited. If you have received this communication in error, please notify the sender.

---

On Dec. 17, 2020:
Subject: FOIA No. 2021-FOIA-00237 - OFAC acknowledgement
Dear Mr. Petti,

RE: FOIA No. 2021-FOIA-00237
OASIS No.: 1163478

Attached is OFAC's acknowledgement of your FOIA request number 2021-FOIA-00237.

If you have any questions regarding this matter, you may email OFACFOIAOffice@treasury.gov<mailto:OFACFOIAOffice@treasury.gov> or contact the FOIA Requester Service Center at 202-622-2500, option 3. Please reference your FOIA No. 2021-FOIA-00237 in any future communications.
Regards,

OFAC FOIA Office
---

On Dec. 16, 2020:
Subject: 2021-FOIA-00237_Ack Letter_OFAC_FINAL.pdf
RE: Your FOIA Request to Treasury, Case Number 2021-FOIA-00237

Dear Mr. Petti :

This email acknowledges the receipt of your Freedom of Information Act (FOIA) request to the U.S. Department of the Treasury, dated 12/14/2020 . You have requested access to the following records:

“Department of Treasury, Office of Foreign Asset Control FOIA Office Department of the Treasury Washington, DC 20220 December 14, 2020 To Whom It May Concern: Pursuant to the Freedom of Information Act, I hereby request the following records: Any foreign policy guidance issued by the U.S. State Department to the U.S. Treasury's Office of Foreign Asset Control regarding applications to work with Syrian oil filed between October 2017 and December 2020.” (Date Range for Record Search: From 10/1/2017 To 12/16/2020)

Your request has been assigned to the Office of Foreign Assets Control (OFAC). OFAC will contact you directly concerning your request. Your request may require further submissions and/or justifications in order to be processed.

When inquiring about your request, please reference FOIA case number 2021-FOIA-00237 and contact the OFAC FOIA Requester Service Center at 202-622-2500, option 3 or via email at OFACFOIAOffice@treasury.gov.

Sincerely,

Michelle Henshaw, Case Manager

FOIA and Transparency

Office of Privacy, Transparency, and Records

---

On Dec. 13, 2020:
Subject: Freedom of Information Act Request: Policy Guidance for Syrian Oil (Department of Treasury, Office of Foreign Asset Control)

To Whom It May Concern:

Pursuant to the Freedom of Information Act, I hereby request the following records:

Any foreign policy guidance issued by the U.S. State Department to the U.S. Treasury's Office of Foreign Asset Control regarding applications to work with Syrian oil filed between October 2017 and December 2020.

In October 2017, the U.S.-backed Syrian Democratic Forces (SDF) seized control of Al-Omar in Deir al-Zour province, home to the largest oil field in Syria. (https://hyperlink.services.treasury.gov/agency.do?origin=https://www.dw.com/en/us-backed-sdf-captures-syrias-largest-oil-field-from-islamic-state/a-41066879)

On December 9, 2020, U.S. Deputy Assistant Secretary of State for Levant Affairs and Special Envoy for Syria Joel Rayburn confirmed to the House Foreign Affairs Committee that a company called Delta Crescent Energy, LLC had been a given a license from the Office of Foreign Asset Control to work with oil fields under SDF control. Deputy Assistant Secretary Rayburn stated that the State Department had issued "foreign policy guidance" in support of Delta Crescent Energy, LLC's application, stating that U.S. officials "support trying to get the economy of northeast Syria up and running to the extent it can under the present conditions of war." (https://hyperlink.services.treasury.gov/agency.do?origin=https://responsiblestatecraft.org/2020/12/09/trump-administration-helped-gop-donors-get-syria-oil-deal/)

Delta Crescent Energy, LLC was granted a license in April 2020, per documents released by the Office of Foreign Asset Control to investigative journalist Zack Kopplin on December 9. Three other companies had applied for a license from the Office and were rejected, according to an earlier report by Kopplin. (https://hyperlink.services.treasury.gov/agency.do?origin=https://newrepublic.com/article/158841/pompeo-trump-steal-oil-kurds-syria-iraq)

I am seeking expedited processing of my request pursuant to 5 U.S.C.§ 552(a)(6)(E) because there is an urgency to inform the public concerning actual or alleged Federal Government activity in a matter of current exigency to the American public..

In response to Rayburn's remarks during the December 9 hearing, Deputy Assistant Secretary Rayburn admitted that the State Department had not discussed an oil for any other company. Congressman Joaquin Castro of Texas noted in response that Delta Crescent Energy, LLC had been co-founded by a prominent donor to Republican Party causes. "We are just leaving what has been a dark period of corruption and graft, sometimes fraud, that has been looked the other way, sometimes, I would argue, encouraged by the Trump administration," Castro said.

Therefore, the public has an urgent need to know as much as possible about Delta Crescent Energy, LLC's relationship with the U.S. Government and with U.S. Government activities in Syria, especially as U.S. troops are risking life and limb to safeguard Syrian oil fields.

President Donald Trump had stated in October and November 2019 that U.S. military forces are remain in Syria "only for the oil" and that they "may have to fight for the oil." At least two U.S. service members have died in Syria since he made these statements, and at least four were injured in an August 2020 skirmish with Russian forces (https://hyperlink.services.treasury.gov/agency.do?origin=https://www.politico.com/news/2020/08/26/us-troops-injured-russian-forces-syria-402347

Foreign countries have condemned the U.S. presence on Syrian oil fields, increasing the risk to Americans stationed there. The Turkish foreign ministry called any U.S. move to extract Syrian oil "utterly unacceptable" (https://hyperlink.services.treasury.gov/agency.do?origin=https://www.hurriyetdailynews.com/turkey-slams-us-over-oil-deal-with-ypg-in-syria-157090), while the Syrian government denounced the rumored deal as "an assault against Syria’s sovereignty" and "a continuation of the U.S. hostile approach towards Syria" (https://hyperlink.services.treasury.gov/agency.do?origin=http://www.sana.sy/en/?p=198923).

Additionally, federal courts have recognized the public's interest in breaking news, which "conveys information the public wants quickly,” “would lose value if it were delayed" (Am. Civil Liberties Union of N. Cal., 2006 WL 1469418 at *6.), and may have an "impact" on the public's political decision-making (Id. at *7).

Syria policy certainly could impact the public's political decision-making process. The Turkish invasion of northeastern Syria in October 2019 caused several congressional hearings and an high volume of news coverage. The public would undoubtedly have an interest in understanding further developments in U.S. policy in the same region of Syria, especially as the transition to a new presidential administration approaches in January 2021.

I am willing to pay up to $100 in fees, but I also believe that I qualify for a fee waiver as a media requester. I am an investigative journalist who has been published in the Daily Beast, the Asia Times, Responsible Statecraft, National Interest, Reason Magazine, America Magazine and the Armenian Weekly, and am requesting these documents in an editorial capacity.

The requested documents will be made available to the general public, and this request is not being made for commercial purposes.

In the event that there are fees, I would be grateful if you would inform me of the total charges in advance of fulfilling my request. I would prefer the request filled electronically, by e-mail attachment if available or CD-ROM if not.

Thank you in advance for your anticipated cooperation in this matter. I look forward to receiving your response to this request within 20 business days, as the statute requires.

Sincerely,

Matthew Petti

View request history, upload responsive documents, and report problems here:
https://hyperlink.services.treasury.gov/agency.do?origin=https://www.muckrock.com/

Filed via MuckRock.com
E-mail (Preferred): requests@muckrock.com

For mailed responses, please address (see note):
MuckRock News
DEPT MR 105775
411A Highland Ave
Somerville, MA 02144-2516

PLEASE NOTE: This request is not filed by a MuckRock staff member, but is being sent through MuckRock by the above in order to better track, share, and manage public records requests. Also note that improperly addressed (i.e., with the requester's name rather than "MuckRock News" and the department number) requests might be returned as undeliverable.
[Image removed by sender.]

From: Matthew Petti

Hello,

My name is Matthew Petti and I am writing in regards to a FOIA request for “any foreign policy guidance issued by the U.S. State Department to the U.S.
Treasury's Office of Foreign Asset Control regarding applications to work with Syrian oil filed between October 2017 and December 2020” I had sent to the U.S. Department of the Treasury on December 14, 2020. According to an email I received on September 3, 2021 — a copy of which you may find attached below — the matter was referred to the Department of State.

Moving forward, whom may I contact to learn about the status of my request? And what reference number should I use to refer to this request? I am looking forward to working with you on this matter.

Best regards,
Matthew

From: Department of Treasury, Office of Foreign Asset Control

Mr. Petti,

The Office of Information Programs and Services is in receipt of your inquiry below. We will follow-up with you as soon as possible to provide a response.

Thank you in advance for your patience.
Regards,

U.S. Department of State

FOIA Requester Service Center

From: Department of Treasury, Office of Foreign Asset Control

**THIS EMAIL BOX IS NOT MONITORED, PLEASE DO NOT REPLY TO THIS EMAIL.** Mr. Petti: Attached is the response to your subject Freedom of Information Act (FOIA) request, 5 U.S.C. § 552 . If you have any questions regarding your request, please contact our FOIA Requester Service Center or FOIA Public Liaison at FOIAstatus@state.gov or 202-261-8484. **THIS EMAIL BOX IS NOT MONITORED, PLEASE DO NOT REPLY TO THIS EMAIL.**

From: Matthew Petti

To whom this may concern,

I hope this message finds you well. My name is Matthew Petti and I am writing in regards to my FOIA request, given the DOS case number C-2021-00042 and the OFAC case number 21-FOIA-00237. You may find attached the February 16, 2024 response letter. Almost the entire content of the documents was redacted under (b)(5) and the name (but not title) of the author was redacted under (b)(6). I believe that the an overly broad redaction process was applied, leading to results that are prima facie absurd, and that disclosure of the information is in the public interest.

Firstly, the name of the Director, Office of Sanctions Policy and Implementation was redacted because it would allegedly "constitute a clearly unwarranted invasion of an individual’s personal privacy." However, the name of that official at the time, Taylor Ruggles, is a matter of public record. His name and photograph have been published in official State Department materials. (See the attached documents "2019-17538.pdf" and "Honiara Ruggles-compressed.pdf") Therefore, I believe that redaction was capriciously applied, and am requesting a review of the redaction process.

Secondly, the content of the documents was redacted as "Interagency or intra-agency communications forming part of the deliberative process." However,
as I mentioned in my initial request letter, then-Deputy Assistant Secretary of State Joel Rayburn disclosed the existence of these documents during a December 9, 2020 hearing of the House Foreign Affairs Committee. He stated that the State Department had given the Office of Foreign Asset Control "foreign policy guidance," which was eventually implemented in the form of a sanctions waiver for Delta Crescent Energy to deal with Syrian oil. This guidance is not a mere deliberation; it was a publicly-acknowledged policy of the Federal government. The actual content of this guidance should be a matter of public record.

My initial request letter cited numerous journalistic articles about U.S. policy towards Syrian oil, underscoring the high level of public interest in the matter, due to the substantial financial interests involved and life-and-death stakes for U.S. personnel in Syria. These articles also underscore a high degree of uncertainly around the actual policy of the Federal government. Given the logical inconsistencies in the redaction process and the pressing questions the redacted information can resolve, I am appealing these redactions.

Best regards,
Matthew Petti

From: Department of Treasury, Office of Foreign Asset Control

Lori Hartmann
Appeals Officer
A/GIS/IPS/PP/LA - room 5420, HST
Office - 202-485-2305, x52305
Teams - 1-771-204-7747

From: Department of Treasury, Office of Foreign Asset Control

The estimated date of completion is July 2024.

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