Highlights
- The U.S. Department of the Treasury's Office of Foreign Assets Control announced a significant relaxation of the comprehensive economic sanctions imposed on Syria through the issuance of General License 25 (GL 25).
- The action was announced in coordination with the U.S. Department of State and Treasury Department's Financial Crimes Enforcement Network, which also announced certain actions to relax certain restrictions on trade with Syria.
- Despite the relief provided by GL 25 and these other actions, several significant restrictions on trade with Syria remain, including, among other things, stringent export controls and blocking sanctions that continue to apply to hundreds of persons in Syria.
The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) on May 23, 2025, announced a significant relaxation of the comprehensive economic sanctions imposed on Syria through the issuance of General License 25 (GL 25). The publication of GL 25, which has no expiration date but may be rescinded at any time with or without notice, follows the Trump Administration's announcement on May 13, 2025, that it would be lifting sanctions on Syria as it seeks to help the country rebuild under the current government led by President Ahmed al-Sharaa, who assumed power after the collapse of the previous regime of Bashar al-Assad in December 2024. Though GL 25 constitutes a relaxation of sanctions on Syria, several significant restrictions and risks for doing business in Syria remain.
Key Effects of GL 25
GL 25 effectively lifts all of the generally applicable restrictions imposed under the Syria Sanctions Regulations (31 C.F.R. Part 542). Prior to GL 25, these restrictions prohibited U.S. persons from undertaking new investments in, exporting services to or engaging in a wide range of activities involving oil and gas from Syria – or from facilitating these activities by non-U.S. persons.
GL 25 also lifts blocking sanctions on the new Syrian government, as in existence on or after May 13, 2025, and authorizes transactions with 28 persons (individuals and entities) currently identified on the Specially Designated Nationals and Blocked Persons List (SDN List), including property or entities owned 50 percent or more by these persons. These include several state-owned or state-affiliated entities involved in the following sectors:
- financial services (e.g., the Central Bank of Syria (CBS), Commercial Bank of Syria, Agricultural Cooperative Bank, Industrial Bank Popular Credit Bank and Saving Bank)
- oil and gas (e.g., Syria Trading Oil Co. (Sytrol) and General Petroleum Corp. (GPC), Syrian Company for Oil Transport, Syrian Gas Co., Syrian Petroleum Co., Banias Refinery Co., Homs Refinery Co., Public Establishment for Refining and Distribution (PERD), and Syrian Ministry of Petroleum and Mineral Resources)
- maritime shipping (e.g., General Directorate of Syrian Ports (GDP), Tartous Port General Co., Syrian Chamber of Shipping, Syrian General Authority for Maritime Transport, Syrian Shipping Agencies Co. and Lattakia Port General Co.)
- aviation (Syrian Arab Airlines – SyrianAir)
Other Relief Granted by State Department and FinCEN
In addition to GL 25, the U.S. Department of State issued a 180-day waiver of the sanctions mandated under the Section 7432(b)(1) of the Caesar Syria Civilian Protection Act of 2019 (22 U.S.C. 8791 note), known as the Caesar Act. The Caesar Act accounts for a relatively small number of persons sanctioned in Syria and places additional restrictions on investment certain regions and industries. By statute, sanctions relief under the Caesar Act cannot be extended beyond 180 days without congressional action. The Treasury Department's Financial Crimes Enforcement Network (FinCEN) also issued an exception under the USA Patriot Act, allowing U.S. financial institutions to open and maintain correspondent accounts for the Commercial Bank of Syria.
Key Caveats and Remaining Restrictions
Though GL 25 marks a significant relaxation of U.S. sanctions on Syria, several key restrictions and other measures that can raise significant risks for business in Syria remain in effect:
- The executive orders under which most of the designations relevant to Syria have been imposed have not yet been formally rescinded. This could allow sanctions to be reimplemented quickly should the U.S. government determine that Syria's new government is not meeting its obligations with respect to sanctions relief. This reflects that the sanctions relief was granted as a "first step," with the expectation that the new Syrian government "will not offer a safe haven for terrorist organizations and will ensure the security of its religious and ethnic minorities" and that the U.S. government "will continue monitoring Syria's progress and developments on the ground."
- Hundreds of persons identified on the SDN List as being located in Syria remain on the list.
- GL 25 does not permit U.S. persons to engage in or facilitate transactions that could benefit Russia, Iran or North Korea. Several of these countries have reportedly continued to operate in Syria. Accordingly, it is essential to conduct rigorous diligence on potential transactions and transaction counterparties to ensure prohibited parties are not involved.
- Property or interests in property blocked under U.S. sanctions as of May 22, 2025, are not automatically unblocked as a result of GL 25.
- Syria remains on the State Department's List of State Sponsors of Terrorism, which has the effect of maintaining the stringent U.S. export controls on Syria under the Export Administration Regulations (EAR) and International Traffic in Arms Regulations (ITAR). This also leaves the Syrian government more vulnerable to civil suits brought by plaintiffs in the U.S. It is possible that over time, this designation could be removed.
- Hay'at Tahrir al-Sham (HTS), with which the new Syrian government and President al-Sharaa have historically been affiliated, remains a designated Foreign Terrorist Organization (FTO). This potentially creates both criminal liability risks under the Anti-Terrorism Act (18 U.S.C. § 2339B), which prohibits the provision of material support to FTOs and sanctions compliance risks.
As noted above, GL 25 could be rescinded at any time, with or without warning, and Caesar Act sanctions relief will expire after 180 days unless Congress acts legislatively.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
