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 has updated its Syria sanctions statutory guidance to reflect the new measures. This step follows similar amendments by the EU to its Syria sanctions regime in February 2025 (see here for our blog). Below, we summarize the key changes introduced by these new regulations.
Companies considering re-entering, or doing business connected with, Syria that were previously restricted from doing so under the revoked sanctions should carefully consider the UK’s sanctions that remain in place, and to the extent applicable: EU sanctions which have not been suspended; and US sanctions against Syria (which currently remain unchanged), as well as broader compliance laws.
Revocation of certain UK sanctions measures
The Amending Regulations revoke certain sanctions measures that the UK considers no longer necessary following the fall of the Assad regime. These include:
- Sectoral sanctions on the energy and transport sectors, which previously prohibited UK persons from, among other activities: carrying out investment activities related crude oil and other energy production; exporting, supplying or making available a number of energy-related and transport-related goods to or for use in Syria or to persons connected with Syria; and importing or acquiring crude oil or petroleum products of Syrian-origin, consigned from or located in Syria or from a person connected with Syria.
- Financial and banking-related sanctions, which previously prohibited UK persons from, among other activities, establishing banking relationships (including correspondent banking relationships) with Syrian banks and financial institutions, acquiring interests in Syrian credit or financial institutions, providing certain insurance and reinsurance services, and selling or purchasing Syrian or Syrian government-guaranteed bonds (unless they were issued between 19 January 2012 and 8 December 2024).
As with the EU’s partial suspension of sanctions, a number of UK sanctions measures remain in place. These include the UK’s measures on exporting and importing certain gold, precious metals and diamonds, exporting or importing military goods or technology, exporting goods and technology related to chemical and biological weapons, internal repression, and interception and monitoring, as well as certain financial-related measures that are now limited to in their application to the regime in Syria from 9th May 2011 to 8th December 2024 led by Bashar Al-Assad (including its public bodies, corporations or agencies, or any person who acted on its behalf or at its direction).
The UK government will continue to monitor the situation and amend the sanctions regime, as necessary, to the extent further oppression is carried out in Syria.
If you have questions regarding this regulatory development, please contact our Trade team for more information.
