On August 24, 2026, the US Department of State rescinded Syria’s designation as a State Sponsor of Terrorism (“SST”) and revoked the designation of al-Nusrah Front, also known as Hay’at Tahrir al-Sham (“HTS”), as a Specially Designated Global Terrorist (“SDGT”). Concurrently, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) removed HTS from the Specially Designated Nationals and Blocked Persons List (“SDN List”), revoked Syria General License 25 (“GL 25”), and updated its Syria-related guidance. The OFAC notice is available here.
As we previously covered, President Trump notified Congress on July 8, 2026 of his administration’s intent to rescind Syria’s SST designation, which triggered a 45-day waiting period before the rescission could take effect. Once the waiting period ended, Secretary of State Marco Rubio authorized the formal rescission. According to the State Department, rescinding Syria’s SST designation and HTS’s SDGT designation “eliminates the final major barriers for private sector investment in Syria.”
Effect of the SST Rescission and the HTS Delisting
As a result of the rescission, Syria is no longer subject to the prohibitions under the Terrorism List Governments Sanctions Regulations (31 CFR Part 596) or 22 USC 7205(a)(1), which had restricted, among other things, US financial transactions with SST-designated governments.
Following revocation of the SDGT designation, HTS is no longer blocked pursuant to the Global Terrorism Sanctions Regulations, 31 CFR Part 594. Treasury has confirmed in its press release that US persons do not require authorization from OFAC to engage in transactions or activities with HTS, provided those activities do not involve blocked persons or otherwise prohibited activities. Because GL 25 had authorized certain transactions that could otherwise have been prohibited due to the role of HTS in the Syrian government, OFAC determined the authorization was no longer necessary and revoked it. Companies that had been structuring Syria-related activity in reliance on GL 25 should consider updating internal authorizations, policies, and counterparty-screening records accordingly, and note that the revocation does not itself authorize activity involving persons who remain on the SDN List.
OFAC also updated FAQs 1220, 1221, and 1222, and removed FAQ 1223. FAQ 1220 now reflects the SST rescission, the HTS delisting, the revocation of GL 25, and the December 18, 2025 repeal of the Caesar Syria Civilian Protection Act of 2019.
Concurrent Counterterrorism Designations
Simultaneously with the HTS delisting, OFAC designated two former HTS affiliates pursuant to Executive Order 13224, as amended: Sa’d Bin Sa’d Muhammad Shariyan al-Ka’bi, designated for having materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, al-Qa’ida; and Jamal Husayn Zayniyah, designated for acting or purporting to act for or on behalf of, directly or indirectly, Hurras al-Din. Both individuals had previously been designated in connection with HTS but have now been redesignated on separate grounds. All property and interests in property of these persons in the United States or in the possession or control of US persons are blocked and must be reported to OFAC, and entities owned 50% or more, directly or indirectly, individually or in the aggregate, by one or more blocked persons are also blocked. Treasury stated that the Syria relief measures do not change its posture with respect to countering global terrorism.
Updated Tri-Seal Advisory and Remaining Restrictions
The Departments of Commerce, State, and the Treasury issued an updated Tri-Seal Advisory on sanctions and export controls relief for Syria, which provides an overview of the relief provided to date. We previously covered the original November 2025 version of the advisory (see our previous blog post here) and the earlier removal of the comprehensive US Syria sanctions program under Executive Order 14312 (see our previous blog posts here and here).
The updated advisory confirms that list-based sanctions remain in place on Bashar al-Assad and his associates, human rights abusers, Captagon traffickers, persons linked to Syria’s past proliferation activities, ISIS and al-Qa’ida affiliates, and Iran and its proxies. Screening Syria-related counterparties therefore remains a key aspect of any transaction related to Syria.
On the export controls side, the advisory notes that on August 24, 2026, the Secretary of State waived the Syria Accountability Act’s prohibition on the export to Syria of items on the US Munitions List, and waived the remaining sanctions under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991, including restrictions on US sales to Syria under the Arms Export Control Act, on licenses for the export of US Munitions List items, on US foreign military financing, and on Syrian-owned or -controlled air transportation to or from the United States. Congress was notified of the latter waiver, which takes effect in 20 days. The advisory further indicates that the Department of Commerce expects to further relax Syria-related restrictions in the Export Administration Regulations following the SST rescission, and that the State Department intends to publish an amendment to the International Traffic in Arms Regulations eliminating the policy of denial for exports and imports of defense articles and defense services destined to or originating in Syria, once the relevant statutorily imposed restrictions are resolved. Companies evaluating Syria-related exports should continue to apply existing licensing requirements until those amendments are published.
We will continue to monitor and update on any further developments in US policy on sanctions and export controls applicable to Syria.
