Department Of Treasury Issues A General License Lifting Some Sanctions On Syria

Authorizations:

GL 25 permits a range of activities that were previously prohibited for U.S. persons. For example, the license authorizes U.S. persons to provide a wide range of financial and other services to people and companies in Syria, pursue new investments there, and engage in transactions involving the new Government of Syria and Syrian-origin petroleum and related products. U.S. banks are also authorized to process transactions for any activities authorized by GL 25.

The authorizations apply only to transactions involving:

• The Government of Syria, as defined in 31 CFR part 542.308, as it exists on or after May 13, 2025 (Note: This includes Syrian President Ahmed al-Sharaa and his administration);
• Any blocked person listed in the GL 25 Annex; and
• Any entity in which one or more of the Annex-listed blocked persons hold a 50% or greater interest, directly or indirectly.

Several statutory prohibitions remain in effect.

OFAC published a FAQ Fact Sheet for GL 25 that notes:

• GL 25 expands on the authorizations contained in GL 24 (January 6, 2025), which authorized transactions with Syrian governing institutions; and transactions involving petroleum, natural gas, and electricity to or within Syria. GL 24 remains in effect until it expires;
• Non-U.S. persons face no U.S. sanctions risk for engaging in GL 25-authorized transactions;
• OFAC will continue to enforce sanctions on Assad, his enablers, serious human rights abusers, drug traffickers, and persons involved in terrorist and proliferation activity;
• U.S. financial institutions may transact with the Central Bank of Syria (but does not unblock any property of the Central Bank of Syria);
• GL 25 does not revoke existing humanitarian licenses, but may overlap with them; and
• Financial institutions may process NGO-related transactions and rely on client attestations unless there is reason to believe a transaction is unauthorized.

The U.S. Department of State issued a 180-day waiver of the Caesar Act, (22 U.S.C. 8791), which places additional restrictions on investment in certain industries, but this relief cannot be extended beyond 180 days without action by Congress.

What is Not Authorized:

The Administration's actions did not repeal any underlying regulations or statutes (including the Syria Accountability Act (export control restrictions) or the Caesar Syria Civilian Protection Act (investment and sectoral restrictions)) that comprise the comprehensive sanctions program targeting Syria.

In particular, the GL 25 action does not:

• Permit transactions and dealings with Syria-related parties on the SDN List (or entities 50% or more owned by one or more such parties) other than those listed in the Annex;
• Unblock any property or interests in property blocked under any sanctions programs in 31 CFR Chapter V as of May 22, 2025;
• Allow transactions involving certain foreign governments or jurisdictions – this includes any transactions for or on behalf of the Governments of Russia, Iran, or North Korea (DPRK), as well as any transactions related to the transfer or provision of goods, technology, software, funds, financing, or services to or from Iran, Russia, or North Korea.
• Permit exports of goods, software, or technology, subject to the ITAR or EAR regulatory requirements. These export control programs continue to restrict nearly all U.S. exports (both military and commercial) to Syria unless a license or other relief under those authorities applies.

Because of the substantial sanctions that remain in place with respect to Syria, U.S. persons are cautioned to carefully assess counterparties and the scope of any transaction to ensure none of these restrictions apply.

On May 28, 2025, the EU adopted legal acts to lift all economic restrictive measures on Syria, with some exceptions for former Assad regime members.

GL 25 lifts certain Syria-related prohibitions imposed under the following sanctions programs:

• Syrian Sanctions Regulations (31 CFR part 542);
• Weapons of Mass Destruction Proliferators Sanctions Regulations (31 CFR part 544);
• Iranian Financial Sanctions Regulations (31 CFR part 561);
• Global Terrorism Sanctions Regulations (31 CFR part 594);
• Foreign Terrorist Organizations Sanctions Regulations (31 CFR part 597); and
• Executive Order 13574 (Concerning Further Sanctions on Iran)

OFAC General License – OFAC General License 25
OFAC Press Release – Treasury Issues Immediate Sanctions Relief for Syria | U.S. Department of the Treasury
OFAC FAQ Sheet – OFAC FAQ for Syria GL 25
OFAC General Information – Syria Sanctions | Office of Foreign Assets Control
EU Lifts Some Sanctions on Syria – Syria: EU adopts legal acts to lift economic sanctions on Syria, enacting recent political agreement – Consilium