On October 1, 2026, the US Department of State published a final rule amending the International Traffic in Arms Regulations (“ITAR“) to remove Syria from the list of countries subject to a policy of denial for licenses and other approvals for exports, imports of defense articles and defense services. The rule took effect on publication of the final rule, and the State Department will now adjudicate applications for licenses or other approvals involving Syria on a case-by-case basis under the new policy.
As we previously reported, the State Department rescinded Syria’s designation as a State Sponsor of Terrorism (“SST“) effective August 24, 2026. The updated Tri-Seal Advisory that the Departments of Commerce, State, and the Treasury issued the same day stated that the State Department would amend the ITAR to eliminate the Syria policy of denial once all relevant statutory restrictions were resolved. (For our coverage of the original November 2025 advisory, see our previous blog post here here.) This final rule implements that policy change so that defense article and defense service transfers to Syria are now reviewed on a case-by-case licensing basis. The State Department also stated that the statutory prerequisites for amending Syria’s status under § 126.1 had been satisfied. These include:
- the rescission of the terrorism-support determination underlying sections 40 and 40A of the Arms Export Control Act (“AECA“), and
- the waiver or removal of the restrictions imposed under the Syria Accountability and Lebanese Sovereignty Restoration Act, the Chemical and Biological Weapons Control and Warfare Elimination Act, and the Child Soldiers Prevention Act.
The rule was issued without a request for public comment under the military and foreign affairs exemption in 5 USC 553(a)(1). Following the amendment, the countries remaining in table 1 to § 126.1(d)(1) are Belarus, Burma, China, Cuba, Iran, North Korea, and Venezuela.
The ITAR licensing requirements that previously applied to Syria-related exports and imports remain unchanged. The rule only changes the review policy the State Department applies to applications for authorization, which will now be considered individually. Companies should continue to screen Syrian counterparties against the US Treasury Department’s Specially Designated Nationals and Blocked Persons List, which still targets a number of Syrian nationals, including Bashar al-Assad and his associates, human rights abusers, Captagon traffickers, and other actors designated under Executive Order 13894, as amended, and other authorities.
We will continue to monitor and update on any further developments in US policy on sanctions and export controls applicable to Syria.
The authors acknowledge the assistance of Alexander Cleveland in with the preparation of this blog post.
