The Sanctions Update, compiled by attorneys from Steptoe's award-winning International Regulatory Compliance team and the Stepwise: Risk Outlook editorial team, publishes every Monday. Guided by the knowledge of Steptoe's industry-leading International Trade and Regulatory Compliance team, the Sanctions Update compiles and contextualizes weekly developments in international regulatory enforcement and compliance, as well as offers insights on geopolitical context, business impacts, and forthcoming risks.
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The Lede
Syrian Leadership Takes Small Steps towards Meeting Requirements for US to Ease Sanctions
Since the fall of the Assad regime in December 2024, the new Syrian leadership has pressed the international community to lift sanctions on the country, with limited success. This month, President Ahmed al-Shara, in an interview with the New York Times, made Syria's case to the American audience, saying that foreign support is essential to the survival of the new government and security in the region.
The US has been a significant holdout, demanding actions, not just talk, from the new Syrian leaders to prove that they do not pose a terrorist threat, given the President's and his key lieutenants' history as al-Qaida jihadists and current adherence to a governance model in accordance with political Islam. President al-Shara and his rebel group, Hayat Tahrir al-Sham, are US-designated for terrorism. From the US perspective, Syria has been a haven for terrorism for decades, having placed the country on the state-sponsored terrorism list in 1979. The US has imposed overlapping sanctions since then to punish the Assad regime for a broad range of lethal actions, from killing Lebanese Prime Minister Rafiq Hariri and enabling Hizballah's capture of the Lebanese state (E.O. 13338, May 2004), to gross human rights abuse and using WMD against the Syrian people during the Syrian civil war (E.O 13572, April 2011; E.O. 13573, May 2011, E.O. 13582, August 2011).
US sanctions impose asset freezes and travel bans on over 600 Syrian officials, Assad supporters, and businesses, and prohibit US persons from financial transactions with Syria, including donations, with a narrow carve-out for humanitarian aid. Beyond punishing, the US has consistently sought a change in the Syrian regime's behavior.
In a meeting on March 18 on the margins of a Syrian donor conference in Brussels, a US official reportedly gave a list of demands to Syrian foreign minister Assad al-Shibani that would need to be met before the US would consider sanctions relief. That list is said to include destruction of chemical weapons stores, cooperation on counterterrorism, restrictions on foreign fighters serving in senior government positions, and cooperation on accounting for Americans who disappeared by Syrian officials during the civil war. In exchange, the US would provide a two-year extension of an existing exemption for transactions with Syrian government institutions and a US statement of support for Syrian territorial integrity.
The general license, issued by the Biden administration on January 6, 2025, for a six-month duration, is narrow, authorizing some energy sales and incidental transactions to allow the entry of humanitarian aid. The Biden administration also dropped the $10 million bounty on the books for the capture of Assad al-Shibani. For the new Syrian government, extension of the general license is not enough, because most financial transactions remain prohibited and international donors remain wary of the sanctions risks. Qatar's Minister of State for Foreign Affairs, Mohammed al-Khulaifi, was in Washington last week, seeking the Trump administration's agreement to further ease sanctions. Qatar has pledged to provide support to the Syrian government by paying public-sector salaries but has held back due to US sanctions.
Reportedly, the Trump administration has now issued an updated set of demands to Damascus, including a ban on all Palestinian militant and political activities and a statement disavowing all jihadist groups. Additionally, the US wants the Syrian government to designate the Iranian Revolutionary Guard Corps as a terrorist organization and clamp down on extremists. The US has started drawing down forces in northeastern Syria and does not want to see Iranian-backed militias surge into the area, establishing new operational bases to launch attacks against US presence in Iraq or Israeli targets.
Thus far, the Syrian government has taken only small steps toward meeting US requirements for sanctions relief. Last week, Syrian authorities arrested two senior Palestinian Islamic Jihad (PIJ) leaders. Syria has been a safe haven for terrorist groups for decades, including PIJ members, where they have planned attacks against Israel from the Palestinian territories and South Lebanon. PIJ leaders have been a priority target for Israeli counterterrorism operations during the Assad regime and since its collapse. It is unlikely that these arrests will be sufficient to meet the expectations of the US. The Syrian government's actions in the next six weeks – before the Biden waiver on humanitarian aid transactions expires - will be key to unlocking more foreign aid. While counterterrorism cooperation tops the US list for sanctions relief, President Trump also has a vested interest in delivering on promises to return home all unjustly detained Americans; even if Adam Tice is no longer alive, the Syrians will need to give an accounting. Furthermore, the Syrian government will need to take action to demonstrably destroy chemical weapons stockpiles. According to estimates by the Organization for the Prohibition of Chemical Weapons (OPCW), there are more than 100 suspected chemical weapons sites, unsecured and posing a major test for Damascus.
Some progress may have been signaled by the visit of Trump ally Rep. Cory Mills (R-FL) to Damascus late last week, after which he briefed President Trump about his meeting with President al-Sharaa and expressed "cautious optimism" about the future of the country. Notably, Mills said that Sharaa expressed openness to Syria joining the Abraham Accords, the agreement under which Arab states, including the UAE and Bahrain, normalized relations with Israel. While the Islamist state is an unlikely candidate for peace with Israel, Sudan's entry into the Abraham Accords in 2021 was part of a deal to remove the transitional state from the State Sponsor of Terrorism list—a path that could be followed by Syria.
The US position stands in contrast to the approach taken by the EU and UK. In February, the EU suspended several sanctions against the country to support its political transition, economic recovery, reconstruction, and stabilization. Sanctions related to the energy and transport sectors have been lifted, and the humanitarian exemption has been extended indefinitely to facilitate the delivery of humanitarian aid, including the facilitation of financial and banking transactions for energy, transport, humanitarian, and reconstruction purposes. Additionally, several entities have been delisted. However, some sectoral measures, such as those related to trade in arms, dual-use goods, equipment for internal repression, and software for interception and surveillance, remain in place. Listings associated with the al-Assad regime, the chemical weapons sector, and the illicit drug trade, notably captagon, also remain. As for the UK, having lifted asset freezes on 24 entities operating in the Syrian energy, transport and finance sectors in February 2025, on April 25, 2025, the UK government announced the lifting of asset freeze sanctions on a further 12 entities, including the Syrian Ministry of Defence, Ministry of Interior, and media companies. The UK's Syria sanctions regime also has been amended to remove UK restrictions on some financial services and energy production in Syria to support essential investment in Syria's energy infrastructure and the Syrian people in rebuilding their country and economy. Like in the EU, sanctions imposed on members of the Assad regime and those involved in the illicit trade in captagon remain in place.
US Developments
US Considering Lifting Sanctions on Russian Energy Assets
The White House is reportedly exploring options to remove sanctions on certain Russian energy assets, including sanctions related to the Nord Stream 2 pipeline, as part of its effort to end the war in Ukraine. As we previously covered, in March, the White House reportedly requested the Departments of State and the Treasury to draft a list of sanctions that could be eased during negotiations with the Kremlin. Reporting also indicated that Moscow was asking companies which sanctions it should prioritize negotiating relief for ahead of its first meeting with the US delegation.
However, Secretary of State Marco Rubio publicly denied the reports that he and White House special envoy Steve Witkoff have discussed lifting energy sanctions as part of a Ukraine deal. In addition, we expect that a decision to lift the sanctions may face considerable opposition from many members of Congress and the European Union, among others.
Treasury Continues to Issue Iranian Energy Designations
The Department of the Treasury's Office of Foreign Assets Control (OFAC) has designated an alleged Iranian liquified petroleum gas (LPG) magnate, Seyed Asadoollah Emamjomeh, and others involved in his "corporate network," for their purported roles in the shipment of Iranian LPG and crude oil to foreign markets. OFAC's actions were taken in furtherance of President Trump's National Security Presidential Memorandum (NSPM-2), which renewed the Trump administration's "maximum pressure" strategy against Iran.
These are the fourth installment of designations that OFAC has announced since the US and Iran first agreed to negotiations over Iran's nuclear program. While the US and Iranian officials have described the ongoing negotiations as constructive, Iran's Foreign Ministry Spokesperson, Esmaeil Baghaei, recently stated that the "continued imposition of sanctions" is in "clear contradiction with the US claim for dialogue" and indicates a "lack of goodwill and seriousness." It remains to be seen how, if at all, the Trump administration's decision to continue applying sanctions pressure on Iran will impact the trajectory of the negotiations.
Lawmakers Push for Engagement with Syria's Interim Government
Senator Elizabeth Warren (D-MA), the Ranking Member of the Senate Committee on Banking, Housing, and Urban Affairs, along with Representative Joe Wilson (R-SC), Member of the House Foreign Affairs Committee, sent a follow-up letter to Secretary Rubio urging the State Department to provide details on the Trump administration's plans with respect to Syria-related sanctions. Sen. Warren and Rep. Wilson claimed that the State Department's response to their initial request was insufficient, especially in light of reports that the US had given the Syrian interim government a list of conditions for partial sanctions relief.
A few days after Sen. Warren and Rep. Wilson's follow-up, Sen. James Risch (R-ID) and Sen. Jeanne Shaheen (D-NH), the Chairman and Ranking Member of the Senate Foreign Relations Committee, respectively, sent a letter to Secretary Rubio and Secretary of the Treasury Scott Bessent encouraging the Trump administration to increase its engagement with the Syrian interim government, including by reducing the sanctions risk in sectors such as agriculture, energy, power grid infrastructure, finance, telecommunications, and education; expanding general licenses (GLs) to provide more flexibility for those on the ground; and providing short-term sanctions relief.
Both of these letters came as Reps. Marlin Stutzman (R-IN) and Cory Mills (R-FL), visited Syria to meet with President Ahmad al-Sharaa. New reports also suggest that the Trump administration is engaged with the Syrian interim government and has increased its requirements for sanctions relief. It remains to be seen whether the Syrian interim government will agree to the Trump administration's conditions, although the last week's arrest of two Palestinian Islamic Jihad leaders signals that Sharaa may be open to complying with US requests to sideline Hamas-linked jihadists that have historically operated freely in Syria.
Senators Express Concern Over De-listing of Hungarian Official
Sen. Shaheen and Sen. Warren released a statement condemning President Trump's decision to remove Antal Rogan from the List of Specially Designated Nationals and Blocked Persons (SDN List). In their statement, Shaheen and Warren questioned the legality of the de-listing on the basis that proper and timely notice was not given to the required Congressional committees under the Global Magnitsky Human Rights and Accountability Act.
Rogan was previously sanctioned by the Biden administration on January 7, 2025, for his alleged involvement in corruption in Hungary. Secretary Rubio announced that the US would be removing Rogan from the SDN List on April 15, 2025, noting that the continued designation was "inconsistent with US foreign policy interests."
UK Developments
UK Announces Wide-Ranging New Package of Russia Sanctions
On April 24, 2025, the UK government announced a new package of Russia trade sanctions, underscoring the UK government's continued focus on increasing economic pressure on the Russian government and degrading its ability to fund the war in Ukraine. The new sanctions further restrict Russian access to UK goods through the imposition of export bans on a range of products, including chemicals, electronics, machinery, plastics, and metals. These measures also more closely align these aspects of UK Russia sanctions with measures imposed by the UK's international partners, including the EU. Additionally, the UK has introduced significant new prohibitions on software and technology, which include (i) prohibitions on the transfer, making available and provision of ancillary services in relation to certain technology associated with energy-related, advanced, and industrial manufactured goods, thereby restricting information flows in relation to these items, and (ii) the imposition of sectoral software and technology prohibitions to prevent the transfer and making available of certain business enterprise, industrial design, and oil and gas related software and technology, as well as the provision of ancillary services related to this software and technology. Finally, synthetic diamonds processed in third countries and helium have been added to existing UK Russia import bans, with the aim of impacting Russian revenue streams critical to funding its war in Ukraine.
EU Developments
EU and China Near Agreement to Lift Sanctions on MEPs
Beijing has reportedly proposed lifting sanctions on several Members of the European Parliament, hinting at a potential reset in EU-China relations amidst the trade tensions sparked by Donald Trump's tariffs. Discussions are reportedly in the final stages, with the European Parliament eager to resume relations once the sanctions are officially lifted.
The sanctions were initially imposed by Beijing in retaliation for EU measures against Chinese officials over human rights violations in Xinjiang. This move had derailed a significant investment agreement between the EU and China. While recent diplomatic engagements suggest a thaw, the European Commission remains cautious about reviving the deal, emphasizing the need for diversified trade partnerships and careful consideration of economic impacts.
EU Extends Sanctions on Myanmar Until April 2026
The Council of the European Union has extended its restrictive measures on Myanmar for another year, until April 30, 2026, citing ongoing severe human rights violations and actions that undermine democracy. These sanctions affect 106 individuals and 22 entities, subjecting them to asset freezes, prohibitions on the provision of funds, and travel bans to the EU. The measures also include an arms embargo, export restrictions on communication monitoring equipment, and bans on dual-use goods for military use. Additionally, military training and cooperation with Myanmar's armed forces are prohibited. The EU continues to withhold financial assistance that could legitimize the junta and remains committed to supporting the people of Myanmar in their quest for democracy and human rights. Further sanctions may be imposed if the situation worsens.
Asia-Pacific Developments
China Sanctions US Congressional Members, Officials and NGO Heads in HK-Related Countermeasure
On April 21, 2025, China's Ministry of Foreign Affairs ("MOFA") announced sanctions against US officials following earlier US sanctions on six Beijing and Hong Kong officials accused of intimidating pro-democracy activists. Chinese Foreign Ministry spokesperson Guo Jiakun stated that the Chinese countermeasures would target US congressmen, officials, and NGO leaders who have performed poorly on Hong Kong-related issues, though specific names were not disclosed. The measures include denial of entry and asset freeze, as outlined by China's Anti-Foreign Sanctions Law. On March 23, 2025, China signed a State Council decree that unveiled the regulation implementing its Anti-Foreign Sanctions Law ("AFSL Implementation Act"). The AFSL Implementation Act further specifies that foreign countries, organizations, or individuals committing, assisting, or supporting acts that endanger China's sovereignty, security, and interests, can become a target of China's countermeasures.
China Denounces 'Illegal' Sanctions on Iran but Supports Nuclear Negotiations
On April 23, 2025, Chinese Foreign Minister Wang Yi reportedly firmly opposed the use of "illegal" sanctions while expressing strong support for Iran's ongoing negotiations regarding its nuclear program with the United States. According to a statement from the Chinese Foreign Ministry, Wang told Iran's Foreign Minister that "China has always been committed to a political and diplomatic solution to the Iranian nuclear issue and is opposed to resorting to force and illegal unilateral sanctions at every turn." Iran updated China on the progress of the "indirect talks" with the US and expressed gratitude for China's constructive stance regarding the nuclear program and the lifting of sanctions.
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