Since we published our blog post on the relaxation of the Syria sanctions over the weekend, there have been two more related developments this week: (1) US guidance on the Syria sanctions relaxed on Friday, May 23, and (2) the EU’s move to formally lift nearly all of its remaining sanctions on Syria.
United States: Guidance on Syria Sanctions Relaxation
On Wednesday, May 28, the Office of Foreign Assets Control (“OFAC”) in the US Treasury Department published a Fact Sheet containing FAQs that provide guidance on the sanctions relaxation measures taken on May 23. The FAQs address the scope of General License 25, the waiver issued under the Caesar Syria Civilian Protection Act, and how these measures should be considered by both US and non-US companies. The guidance is focused on the specific measures taken on Friday and is consistent with the points we raised in our last blog post. Our blog post identifies the key remaining risks, including US export controls (which have not been relaxed), the fact that the underlying sanctions framework remains in place, sanctioned parties and Foreign Terrorist Organizations, Syria’s continued designation as a State Sponsor of Terrorism, US antiboycott laws, and financial risks.
The introduction to OFAC’s Fact Sheet notes that General License 25 and the waiver are “significant steps in support of a broader U.S. government effort to remove the full architecture of sanctions imposed on Syria due to the abuses of the Bashar al-Assad regime”. This suggests that there is more to come. We will share updates on this blog.
European Union: EU moves to lift nearly all economic sanctions on Syria
Effective from 29 May 2025, the EU moved to lift nearly all remaining economic sanctions on Syria as the EU Council formally adopted legal acts to this end. This move follows from the EU Council’s announcement of 20 May 2025 to lift certain EU economic sanctions against Syria that were introduced in 2011, acknowledging the need for economic recovery and stability after the fall of the Assad regime in Syria. The adoption follows a wider trend of relaxation of sanctions against Syria by other jurisdictions, including the US and the UK (see our blog post on this topic here).
While the EU lifts most of its economic sanctions on Syria, not all EU sanctions on Syria will be removed. In particular, the EU will maintain and introduce the following measures:
- Sanctions based on security grounds: the arms embargo and export restrictions on equipment and technology that could be used for internal repression will remain in place;
- Targeted sanctions related to Assad’s regime: designated persons linked to Syria’s former regime will continue to be subject to asset freezes and travel restrictions until 1 June 2026; and
- New restrictive measures: the EU will introduce additional targeted sanctions against individuals and entities seen as violating human rights or contributing to instability in Syria. In this respect, the EU already introduced new restrictive measures under the EU Global Human Rights Sanctions Regime, targeting two individuals and three entities for human rights abuses.
With this lift, the EU has eased various economic sanctions on Syria, including those that were previously suspended in February 2025 (see our blog post here). Notably, the EU Council has now delisted 24 entities as designated parties under the EU’s asset freezing regime, including the Central Bank of Syria, the Commercial Bank of Syria and several other Syrian banks. This move aims to facilitate financial flows and allow for increased commercial activity in Syria. In line with this, the EU also removed prior restrictions on transport and certain financial services, such as restrictions to sell or purchase Syrian public bonds, to provide insurance to the state of Syria and those for EU financial institutions to open new bank accounts with Syrian banks. Other measures that have been removed include restrictions on trade in crude oil and petroleum, jet fuel and fuel additives, luxury goods, gold, precious metals and diamonds, restrictions on participation in infrastructure projects and restrictions on financing of certain enterprises.
The legal act amending Regulation (EU) 36/2012 concerning restrictive measures in view of the situation in Syria can be found here.
