In less than two weeks, we have seen Syria go from one of the most heavily sanctioned countries on the planet to a country well on the road to establishing normal trade relations with the Western world.
The latest flurry of developments started on May 13, 2025, when President Trump caught much of the world by surprise when he said in a speech in Riyadh: “I will be ordering the cessation of sanctions against Syria in order to give them a chance at greatness.”
The next day, there was a face-to-face meeting between President Trump and Syria’s interim President Ahmad al-Sharaa, marking the first meeting between a US and Syrian President in 25 years. Just over a week later, on May 23, the core US sanctions targeting Syria were effectively relaxed (though not the US export controls embargo, at least not yet). In the midst of everything, the European Union also announced it would lift its sanctions against Syria. While the United Kingdom did not make any new announcements this past week, it previously announced a relaxation of its sanctions in April. All of this is happening in a context where the situation in Syria remains fragile, with recent clashes between pro-Government groups and certain minorities.
What does this mean in practice? What is the current status of the US, EU, and UK sanctions against Syria? What has been relaxed, and what restrictions remain?
United States: Syria sanctions relaxed, but export controls and other risks remain
What US sanctions have been relaxed?
The US Government has maintained a comprehensive embargo against Syria since 2011, implemented through both sanctions and export controls. Under the sanctions, US Persons have been prohibited from almost any business involving Syria or the Government of Syria, while export controls have prohibited virtually all exports/reexports to Syria of goods, software, or technology subject to US jurisdiction.
On May 23, 2025, the US Treasury Department announced the relaxation of US sanctions targeting Syria through several actions that, taken together, effectively mean that US Persons are no longer prohibited from doing business in Syria. Of course, there’s a bit more to it than that, so we have summarized these actions here:
- OFAC General License No. 25: The Office of Foreign Assets Control (“OFAC”) issued GL 25, which effectively relaxes the sanctions against Syria by authorizing “all transactions” with Syria and the Government of Syria, defined to include Syrian President Ahmed al-Sharaa and his government.
GL 25 also authorizes all transactions with the Specially Designated Nationals (“SDNs”) identified in the Annex (which includes SDNs designated under other sanctions programs) and non-designated entities 50% or more owned by these parties. The Annex includes key economic actors in Syria, including the Central Bank of Syria, Syrian Arab Airlines, Commercial Bank of Syria (“CBoS”), and several other Syrian banks. These parties remain SDNs but US Persons are authorized to deal with them so long as GL 25 remains in effect.
GL 25 supersedes the more limited sanctions relaxation for certain dealings with the Government of Syria that OFAC implemented with General License No. 24. We previously blogged about GL 24 here. In addition, GL 25 does not have an expiration date, unlike the upcoming one found in GL 24.
GL 25 does not unblock property (e.g., funds, contracts, equipment) previously blocked in connection with the parties identified in this authorization. It also does not authorize any dealings with the governments of Iran, North Korea, or Russia in Syria. - Financial Crimes Enforcement Network (“FinCEN”) Exceptive Relief for CBoS: Since April 2006, CBoS has been targeted by special measures under Section 311 of the USA PATRIOT Act. These FinCEN special measures prohibited US financial institutions from opening and maintaining correspondent accounts for CBoS and required them to engage in due diligence to prohibit indirect access to such accounts by CBoS. FinCEN published Exceptive Relief that lifts these prohibitions.
- State Department Secondary Sanctions Waiver: Under the Caesar Syria Civilian Protection Act (“Caesar Act”), the US Government has had authority to impose US secondary sanctions (e.g., SDN designations) on non-US parties engaging in certain dealings with the Government of Syria and others operating in Syria. We previously blogged about the Caesar Act here. Secretary of State Marco Rubio signed a waiver under the Caesar Act that provides that, for 180 days, US secondary sanctions will not be used against non-US parties engaging in transactions covered by GL 25.
The State Department’s press release about these US developments describes them as a “first step in delivering on [President Trump]’s vision of a new relationship between Syria and the United States.”
What restrictions and risks remain?
The relaxation of the US sanctions against Syria is a major development that dramatically changes the sanctions landscape. That said, some meaningful restrictions and risks remain:
- Sanctions Framework Remains in Place: Because of how this relaxation was implemented, it would be straightforward for the Trump Administration to reverse course and reimpose these sanctions if it wanted to do so. OFAC issued a general license rather than remove the underlying regulations, so OFAC could simply revoke the general license. The secondary sanctions waiver is for 180 days so it will need to be revisited by the 180-day mark in order to be extended, or not.
- US Export Controls Embargo: The US Commerce Department has not announced changes to US export controls targeting Syria found in Section 746.9 of the Export Administration Regulations (“EAR”). Under these controls, the export, reexport, and transfer of virtually all goods, software, and technology subject to the EAR (except for EAR99 food and medicine) triggers a licensing requirement. These export controls are mandated by the Syria Accountability and Lebanese Sovereignty Restoration Act of 2003 so additional action would be needed under that statute to relax them. Syria also remains subject to a US arms embargo under Section 126.1 of the International Traffic in Arms Regulations.
- SDNs: There remain various SDNs in Syria that do not benefit from GL 25, so continued screening and due diligence of Syria-related transactions is recommended. For example, Hay’at Tahrir al-Sham (“HTS”), the jihadist organization previously led by Syrian President Ahmed al-Sharaa under the nome de guerre Abu Muhammad Al-Jawlani, is not named on the Annex (though Al-Jawlani, also an SDN, does appear on the Annex).
- Foreign Terrorist Organizations: Some of the Syrian parties benefitting from GL 25 are designated as Foreign Terrorist Organizations (“FTOs”), as is HTS. US Persons and non-US persons subject to US jurisdiction as set out in 18 U.S.C. § 2339B(d) may face criminal liability for knowingly providing “material support” to FTOs, a risk that cannot be entirely eliminated by GL 25 or any other general license. “Material support” is broadly defined to mean “any property, tangible or intangible, or service” such as currency, monetary instruments, and financial securities, but excluding medicine and religious materials. The US Department of Justice has historically used the material support statute to prosecute companies that have made payments to FTOs. That said, US prosecutors reviewing dealings with FTOs are likely to take into account whether such transactions are authorized by GL 25.
- State Sponsor of Terrorism: The designation of Syria as a State Sponsor of Terrorism has not been lifted. Unless it is lifted, this could limit the ability to relax export controls. The SST designation also comes with negative policies towards loans by international financial institutions and a prohibition on assistance under the US Food for Peace, Peace Corps, and Export-Import Bank programs.
- Antiboycott: Syria participates in the Arab League boycott of Israel and is named on the US Treasury Department’s official list of boycotting countries. US antiboycott laws prohibit or penalize US companies from complying with (or agreeing to comply with) the boycott. The receipt of boycott requests may trigger reporting requirements to the US Commerce or Treasury Departments. US companies pursuing business with Syria should be on the lookout for potential boycott requests and should make sure their antiboycott compliance programs are up to date and fit for purpose.
- Financial Risks: Even with the relaxation of sanctions and FinCEN’s exceptive relief for CBoS, banks might continue to “derisk” Syria by refusing to process payments to or from Syria. In addition, companies’ loan agreements and covenants may contain language prohibiting business with Syria – we recommend conducting a review of those types of agreements to avoid a situation where initiating business with Syria could cause a breach.
European Union: Remaining Syria sanctions to be relaxed
Since our earlier blog post on the EU’s partial suspension of its sanctions against Syria, the EU Council issued a statement on May 20, 2025 confirming its decision to lift all remaining EU economic sanctions against Syria. These EU sanctions have been in place since 2011. They are narrower and more targeted than US sanctions. Measures have included a ban on internal repression equipment and other export and import restrictions, travel restrictions, an asset freeze on designated persons, a prohibition on participation in certain infrastructure projects and investment in such projects, and restrictions on the provision of financial services, among others.
The EU will maintain sanctions directed at the Assad regime and those aimed at safeguarding the security of the Syrian people. The EU arms embargo and export restrictions on equipment and technology that could be utilized for internal repression will remain in effect. Additionally, the EU announced its intention to implement new restrictive measures against human rights violators and entities contributing to instability in Syria.
Given the narrower scope of EU sanctions on Syria and the fact that some sanctions will be retained and new restrictive measures added, the impact from lifting EU sanctions on Syria is not likely to be as significant for companies as the lifting of US sanctions.
United Kingdom: Partial suspension of Syria sanctions
As reported in our earlier blog post, the UK partially suspended its sanctions targeting Syria – which were similar in scope to EU sanctions on Syria – focusing on relaxing sanctions on key sectors of the economy, namely energy and transport, and banking and finance.
If you have questions regarding these regulatory developments, please contact our Trade team for more information.
