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Sanctions Targeting Syria

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On June 30, 2025, President Trump issued Executive Order 14312 (the “Syria EO”) terminating the U.S. comprehensive sanctions program targeting Syria, while also continuing to maintain and expand certain sanctions targeting former Syrian President Bashar al-Assad and others associated with the former Syrian regime. In addition, the U.S. State Department revoked the designation of Hay’at Tahrir al-Sham’s (“HTS”) as a Foreign Terrorist Organization (“FTO”) on July 8, 2025. OFAC has taken the following actions to implement…

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…

On 24 April 2025, the UK government published the Syria (Sanctions) (EU Exit) (Amendment) Regulations 2025, which took effect on 25 April 2025 (“Amending Regulations”). These new regulations amend the Syria (Sanctions) (EU Exit) Regulations 2019 to partially suspend a number of significant sanctions that have been in place for over a decade to reflect the developments to the political situation in Syria following the fall of the Assad regime in December 2024. The UK…

As anticipated in its press release, the EU yesterday published in the Official Journal the first legal instruments underpinning its decision to progressively suspend its sanctions against Syria: Decision 2025/406/CFSP, Council Regulation 2025/407 and Council Implementing Regulation 2025/408. The measures include the suspension of a significant number of sanctions which have been in place for over a decade, most recently contained within Council Regulation 36/2012, as summarised below. Companies considering business in Syria previously restricted…