On June 30, the Department of the Treasury's Office of Foreign Assets Control (OFAC) implemented the President's Executive Order "Providing for the Revocation of Syria Sanctions," (Syria EO) which removes U.S. sanctions on Syria, effective July 1, 2025. The Syria EO revokes previous orders that placed comprehensive sanctions on Syria, while also continuing sanctions against those associated with Bashar Al-Assad, his regime, and other "destabilizing regional actors."
Pursuant to the Syria EO, OFAC removed 518 individuals and entities from the List of Specially Designated Nationals and Blocked Persons (SDN List) sanctioned under the Syria sanctions program while also designating 139 individuals and entities affiliated with the previous regime under Executive Order 13894. The full list of changes to the SDN List can be found here.
The lifting of the sanctions comes after what the administration calls "positive actions taken by the new Syrian government under President Ahmed al-Sharaa." It is important to note that pending or future OFAC investigations or enforcement actions related to apparent violations of the Syrian Sanctions Regulations that occurred prior to July 1, 2025 may still be carried out.
The lifting of sanctions also comes after the issuance of Syria General License (GL) 25, which authorizes certain transactions previously prohibited under the Syria Sanctions Regulations, including new investment in Syria and providing services to people and companies in Syria, among others. For more information, see OFAC's GL 25 factsheet here.
As noted, sanctions are retained against Al-Assad, his associates, and other destabilizing regional actors under this executive order. The individuals and entities are designated and divided into eight categories:
- Former Officials of the Assad Regime;
- Persons Acting for or On Behalf of Former Assad Regime Officials;
- Persons Threatening the Peace, Security or Stability of Syria;
- Persons Engaged in Activities or Transactions Related to Captagon;
- Persons Providing Material Support to the Former Assad Regime;
- Persons Providing Material Support to an SDN;
- Persons Owned or Controlled or Acting on Behalf of an SDN; and
- Adult Family Members of Certain SDNs.
Sanctions against the former regime of Al-Assad and associated parties will be maintained under a new program called "Promoting Accountability for Assad and Regional Stabilization Sanctions."
OFAC also issued four new Syria Frequently Asked Questions (FAQs 1220-1223). These clarify that U.S. financial institutions can now establish relationships with Syrian financial institutions, that food and medicine exports to Syria do not need a specific license from OFAC, and that persons can continue to rely on GL 25 following the Syria EO.
Syria remains subject to strict U.S. export control restrictions, enforced by both the Department of Commerce's Bureau of Industry and Security (BIS) and the Department of State's Directorate of Defense Trade Controls (DDTC). Under current BIS rules, virtually all exports or reexport to Syria of items regulated by the Export Administration Regulations (EAR) are prohibited without a BIS license or applicable license exception, as described under 15 C.F.R. § 746.9. This includes U.S.-origin goods and technology, regardless of location, as well as foreign-made items containing more than 10% controlled U.S. content.
From the DDTC side, Syria is designated as a proscribed destination under the International Traffic in Arms Regulations. As a result, there is a general policy of denial for any license requests related to defense articles or services involving Syria (per 22 C.F.R. § 126.1(d)(1)).
We expect that other U.S. government agencies will soon update their regulations to align with recent changes. However, at this time, the lifting of sanctions under OFAC does not automatically mean your transaction is free from other licensing requirements. Agencies such as the Department of Commerce or the State Department may still require authorization, depending on the nature of the goods or services involved.
If your company is considering doing business in Syria, it is critical to avoid transactions involving items or funds that were previously exported or transferred in violation of U.S. sanctions. For instance, providing spare parts for equipment that was originally exported to Syria without proper authorization could still be treated as a violation of U.S. export control laws.
* Legal Assistant Sean Church contributed to this blog post.
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