On June 30, 2025, President Trump issued Executive Order 14312 (the “Syria EO”) terminating the U.S. comprehensive sanctions program targeting Syria, while also continuing to maintain and expand certain sanctions targeting former Syrian President Bashar al-Assad and others associated with the former Syrian regime. In addition, the U.S. State Department revoked the designation of Hay’at Tahrir al-Sham’s (“HTS”) as a Foreign Terrorist Organization (“FTO”) on July 8, 2025.
OFAC has taken the following actions to implement the Syria EO:
- OFAC revoked the following six EOs that formed the foundation of the U.S. Government Syria sanctions program: EO 13338 of May 11, 2004; EO 13399 of April 25, 2006; EO 13460 of February 13, 2008; EO 13572 of April 29, 2011; EO 13573 of May 18, 2011; and EO 13582 of August 17, 2011.
- OFAC removed 518 individuals and entities from the List of Specially Designated Nationals and Blocked Persons (the “SDN List”) sanctioned under the Syria sanctions program. The list of removed individuals and entities is available here, and includes the Central Bank of Syria. All property and interests in property of such persons are now unblocked.
- The Syria EO expanded the national emergency declared in EO 13894 to allow for the continuation of sanctions against Bashar al-Assad, his associates, and other destabilizing regional actors. OFAC designated 139 individuals and entities affiliated with the prior regime under that authority and other Iran-and terrorism-related authorities. The targeted individuals and entities are identified in the Annexes here.
- OFAC issued new FAQs, which indicate that OFAC Syria General License No. 25 (“GL 25”) remains available as needed. The FAQs also indicate that U.S. persons are no longer prohibited from providing financial services to Syria, processing payments on behalf of third country financial institutions involving Syrian financial institutions, or conducting transactions with the new Government of Syria and Syrian financial institutions, provided that none of the involved parties are on the SDN List.
- OFAC has indicated it will remove the Syrian Sanctions Regulations (the “SySR”) from the Code of Federal Regulations. The remaining Syria-related sanctions will be part of the new OFAC Promoting Accountability for Assad and Regional Stabilization Sanctions (“PAARSS”) program.
In addition, there have been several notable developments relating to the U.S. Government’s Syria export control program, the Caesar Act, and revocations of certain terrorism-related designations:
- Syria Export Controls: The Syria EO waived the requirements to impose certain export controls on Syria under the Syria Accountability and Lebanese Sovereignty Restoration Act of 2003, and under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991. BIS has not yet amended the Export Administration Regulations (“EAR”) to relax U.S. export controls targeting Syria but these waivers provide legal authority for BIS to relax export controls on items listed on the Commerce Control List. Eventual removal of Syria’s designation as a State Sponsor of Terrorism means that anti-terrorism controls could be removed. BIS could proceed to remove controls on EAR99 items because the State Sponsor of Terrorism licensing requirements only apply to controlled items under section 1753(a) and (c) of the 2019 NDAA.
- The Caesar Act: The Syria EO directed the U.S. Secretary of State to evaluate suspending sanctions under the Caesar Syria Civilian Protection Act of 2019 (“the Caesar Act”), a law that imposed sanctions on Syria in connection with the former Assad regime’s war crimes against civilians. The State Department previously waived certain secondary sanctions imposed under the Caesar Act for a renewable 180-day period on May 23, 2025.
- Terrorism-related Designations: The Syria EO directed the Secretary of State to review HTS’s designation as an FTO, HTS and Ahmed al-Sharaa’s designations as Specially Designated Global Terrorists (“SDGTs”), and Syria’s designation as a State Sponsor of Terrorism, and also to explore avenues for sanctions relief at the United Nations to support stability in Syria. The U.S. State Department revoked the designation of HTS as a FTO on July 8, 2025.
Our prior blog post on earlier U.S. Government actions relaxing sanctions targeting Syria sanctions is available here.
