On November 10, 2025, the US Department of the Treasury, US Department of State, and US Department of Commerce issued a Tri-Seal Advisory (see here) summarizing the current scope of US sanctions and export controls relief measures applicable to Syria. The document serves as a consolidated reference point for the actions taken so far to relax US sanctions and export controls for Syria, including those aimed at facilitating humanitarian assistance and early recovery efforts.
The advisory summarizes previously implemented measures, including the removal of comprehensive US sanctions on Syria, the waiver of certain sanctions designation authorities, the easing of certain export controls under the US Export Administration Regulations (EAR), and available general licenses and license exceptions, among others. You can find our previous blog posts about these developments here, here, here, and here. The advisory also reminds companies that Syria’s designation as a State Sponsor of Terrorism remains under review and that most Commerce Control List items still require US export/reexport licenses for Syria under the EAR. While the advisory does not introduce new policy actions, it notes two recent developments:
- The November 7, 2025 delisting of Syrian President Ahmed Al-Sharaa and Interior Minister Anas Hasan Khattab from the Specially Designated Global Terrorist list, which means that US persons are no longer prohibited from engaging in dealings with those individuals or required to block their property or interests in property. It also means that non-US persons will not face US secondary sanctions risk from engaging in transactions with those individuals as they would have prior to their delisting.
- The U.S. Department of Stateās renewal of the 180-day suspension of sanctions under the Caesar Syria Civilian Protection Act of 2019, effective November 6, 2025 (see full announcements here and here).
The State Department has emphasized that the Caesar Act suspension is intended to support the Syrian people by enabling access to essential services and reconstruction efforts but warns that the suspension does not affect prohibitions on certain transactions involving the governments of Russia and Iran, or the transfer of provisions of Russian-origin or Iranian-origin goods, technology, software, funds, financing, or services.
We will continue to monitor and update on any further developments in US policy on sanctions and export controls applicable to Syria.
