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 by the suspended measures will need to carefully consider the EU sanctions which remain in place; corresponding developments relating to other sanctions programmes relating to Syria (including those of the US and UK); broader corporate compliance laws, and the potential risk of the EU’s sanctions falling back into place. Please see our recent blog post on US sanctions developments relating to Syria here.
As always, please get in touch with your usual contacts within the Baker McKenzie global trade compliance team for support.
Summary of suspended EU sanctions measures
With a view to encouraging an inclusive transition in Syria, enabling humanitarian relief, economic recovery, reconstruction and stabilisation, and to help facilitate the return of Syrian nationals to their country, the EU is taking the following measures, which are in force as of today, 26 February 2025:
- Suspension of sectoral measures in the energy and transport sectors, which previously prohibited:
- imports, purchases and transport of crude oil and petroleum products from Syria or with Syrian origin, and the provision of related services;
- the export, sale, supply and transfer of equipment and technology related to the exploration, production and refining of crude oil and natural gas, including the liquefaction of natural gas, in Syria, and the provision of related services;
- exports, sales, supplies and transfers of jet fuel and fuel additives to Syria, and the provision of related services;
- the sale, supply, transfer or export of equipment or technology for use in the construction or installation in Syria of new power plants for electricity production, and the provision of related services; and
- financing projects pertaining to exploration, production or refining of crude oil, and the construction or installation of new power plants for electricity production.
- Suspension of individual sanctions designations and banking-related sanctions
- To ensure the effectiveness of the suspensions of the restrictive measures, five entities have been removed from the list of natural persons, entities, or bodies subject to the freezing of funds and economic resources and to the prohibition of making funds and economic resources available to them. This includes four banks (Industrial Bank, Popular Credit Bank, Saving Bank, Agricultural Cooperative Bank), and one airline (Syrian Arab Airlines). As regards to the Central Bank of Syria, it is now allowed to make funds and economic resources available to it but any funds and economic resources belonging to, owned, held or controlled by it and located outside Syria as of 27 February 2012 remain frozen.
- In this regard, the Council introduced certain exemptions to the prohibition of establishing banking relations between Syrian banks and financial institutions within the territories of the member states. These exemptions allow transactions associated to the energy and transport sectors and transactions needed for humanitarian and reconstruction purposes.
- Suspension of the prohibition on the sale, supply, transfer or export of Syrian denominated banknotes and coinage to the Central Bank of Syria.
- Suspension of the access ban to EU airports by cargo flights operated by Syrian carriers and flights operated by Syrian Arab Airlines.
- Exemptions to the prohibitions on exports of luxury goods to Syria for personal use. Bringing luxury items to Syria is now permitted provided that:
- the sale, supply, transfer or export is for personal use of natural persons travelling from the European Union or members of their immediate families travelling with them, and
- the goods consist of personal effects, household effects or vehicles owned by those individuals and not intended for sale in Syria.
- Perpetuating the existing humanitarian exemption from asset freeze measures, which was previously foreseen only until 1 June 2025.
Importantly, a number of sanctions remain in place, including the designations of a number of parties connected to the Assad regime, and the prohibitions and reinforced export controls around chemical weapons, illicit drug trade, arms trade, dual-use goods, equipment for internal repression, software for interception and surveillance, and Syrian cultural heritage goods.
The Council will continue to closely monitor the evolution of the situation in Syria, to ensure the appropriateness of (i) its restrictive measures considering the objectives being pursued and assess potential additional suspensions; and of (ii) the continued suspension of and exemptions to the restrictive measures herein described.
