On January 6, 2025, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued new General License No. 24 (“GL”), which authorizes certain transactions formerly prohibited by several US sanctions programs. OFAC also issued eight new Syria Frequently Asked Questions (“FAQs”) and amended one existing FAQ, as part of its effort to ease certain trading restrictions after rebel forces toppled Syrian President Bashar al-Assad’s regime on December 8, 2024.
General License No. 24
This GL authorizes the following transactions through 12:01a.m. EST, on July 7, 2025:
- Transactions with “governing institutions” (defined below) in Syria following December 8, 2024;
- Transactions in support of the sale, supply, storage, or donation of energy, including petroleum, petroleum products, natural gas, and electricity, to or within Syria; and
- Transactions that are ordinarily incident and necessary to processing the transfer of noncommercial, personal remittances to Syria, including through the Central Bank of Syria.
The GL is subject to various limitations and conditions. For example, it does not authorize any transactions involving military or intelligence entities, or any persons acting for or on behalf of such entities; transactions prohibited by OFAC’s regulation restricting importation into the United States of petroleum or petroleum products of Syrian origin; or transactions prohibited by OFAC’s regulation restricting new investment in Syria, except contributions of funds for salaries or wages of employees of “governing institutions” in Syria that are consistent with this regulation.
Syria FAQs
OFAC issued eight FAQs, and also amended existing FAQ 227, which provide further guidance on the GL. We summarize key aspects of these FAQs below:
- FAQ 1205 states the GL is intended to ensure that US sanctions do not impede essential governance-related services in Syria, including for the provision of public services or certain transactions related to energy or personal remittances.
- FAQ 1206 defines “governing institutions” for purposes of the GL to include departments, agencies, and government-run public service providers (e.g., public hospitals, schools, and utilities) at the federal, regional, or local level in Syria, including entities involved with Hay’at Tahrir al Sham, which is the Islamist militant group primarily responsible for overthrowing the Assad regime. As noted above, the GL does not permit transactions involving military or intelligence entities, or persons acting on their behalf.
- FAQ 1207 provides examples of transactions that are authorized by the GL, including the provision of services to, or the payment for services received from, Syrian “governing institutions” (e.g., Ministry of Health, Ministry of Education, Ministry of Water Resources), even when the ministry or leadership of the institution is considered blocked. Other authorized transactions include the payment of taxes, fees, or import duties to, and the negotiation of contracts or other agreements with, Syrian “governing institutions.”
- FAQ 1208 clarifies, similar to other sanctions programs, that transactions with “governing institutions” are authorized by the GL, even if a designated individual has a leadership role in that institution. Other than for the purpose of effecting certain payments to “governing institutions” or for the purchase or receipt of permits, licenses, public utility services, or other public services in Syria, however, US persons must abstain from making financial transfers to blocked persons.
- FAQ 1210 confirms that the GL does not remove the restrictions placed on Syria due to its designation by the US State Department as one of four State Sponsors of Terrorism.
- FAQ 227 expands the authorization of personal remittances to ensure consistency with the GL, subject to certain conditions.
