On May 23, 2025, the U.S. Department of the Treasury (Treasury), including its Office of Foreign Assets Control (OFAC) and the Financial Crimes Enforcement Network (FinCEN), along with the U.S. Department of State, took actions to provide broad sanctions relief to Syria. The actions follow President Trump's May 13, 2025 announcement in Riyadh, Saudi Arabia that he would soon be "ordering the cessation of sanctions against Syria in order to give them a chance at greatness." This significant policy shift came at the urging of Saudi Arabia's and Turkey's leaders, in response to which President Trump announced that the United States would provide relief to the new government in Syria. In December 2024, Syrian rebels, led by now-interim President Ahmed al-Sharaa, toppled the country's former dictator Bashar al-Assad after a 13-year civil war. Significant sanctions were imposed over decades in response to abuses of the Assad family regime, which first came into power in 1971 and engaged in acts of terrorism, use of chemical weapons, political repression, and human rights atrocities perpetrated during the civil war, as well as support for terrorist proxy groups backed by Iran in Lebanon and Iraq.
The relief measures by the United States follow the gradual lifting of sanctions by the European Union (EU) and the United Kingdom (U.K.). The EU, which began easing sanctions against Syria in February 2025, announced that it lifted most of its sanctions on May 28, 2025. Likewise, the U.K., which began lifting sanctions in March 2025, introduced on May 28, 2025 legislation to amend and revoke measures targeting several sectors of the Syrian economy.
Background
The web of U.S. sanctions against Syria, which dates back to 1979, is complex. Some sanctions target the country as a whole (such as prohibitions on the provision of services, arms embargoes, and restrictions on most dual-use good exports), some target the government and its institutions and entities (such as restrictions on transacting with the Syrian Central Bank), and some target particular persons (such as former President Assad and, according to the Congressional Research Service, 681 other entities and individuals listed on OFAC's Specially Designated Nationals and Blocked Persons list (SDN List) as of February 2025). This is important because whether and how any particular sanction may be rolled back depends on the authority under which that sanction was imposed. For example, many of the sanctions levied against Syria are located in the Syrian Sanctions Regulations (SySR), 31 C.F.R. Part 542, and were imposed pursuant to executive order, legislation from Congress, or a combination of both. Those imposed exclusively pursuant to an executive order may be lifted by the president at any time, while those imposed pursuant to congressional action may in some cases be temporarily waived, but otherwise require congressional action to fully eliminate. For example, the Syria Accountability and Lebanese Sovereignty Restoration Act of 2003 and Caesar Syria Protection Act of 2019 (Caesar Act), which imposed additional sanctions on Syria, require congressional action to permanently remove.
Relief Measures
The United States has put several different relief measures into place in order to roll back these various sanctions. On May 23, 2025, OFAC issued General License No. 25 (GL 25), authorizing all transactions prohibited by the SySR other than those involving blocked persons who are not specifically identified in the Annex to GL 25. GL 25 specifically exempts (and thus allow transactions with) the government of Syria under President al-Sharaa and 28 other blocked persons and entities, including Syrian Arab Airlines, the Central and Commercial Banks of Syria (and other major banks), Syrian gas and petroleum companies and refineries, Syrian ports, and other key players in Syria's economy. GL 25 also authorizes transactions with entities owned 50% or more by such exempted persons and entities. All other sanctioned parties — and any other parties owned 50% or more by those sanctioned parties — remain prohibited despite the relief measures.
Also on May 23, 2025, Secretary of State Marco Rubio waived secondary sanctions imposed by Congress in the Caesar Act for 180 days. Those sanctions require the U.S. executive branch to sanction third-country individuals and companies that engage in certain types of business — including reconstruction — with Syria, its government, and individually sanctioned entities in Syria. They can be waived upon a finding by the Secretary of State that waiver is "in the national security interests of the United States." Finally, also on May 23, 2025, FinCEN issued exceptive relief to permit U.S. financial institutions to maintain correspondent accounts for the Commercial Bank of Syria.
According to Treasury's press release, the recent measures are "intended to help rebuild Syria's economy, financial sector, and infrastructure, in line with U.S. foreign policy interests." At their core, the measures authorize new investment in Syria, the provision of financial and other services to people and companies in Syria, transactions with the new government of Syria, and transactions involving the blocked parties listed in GL 25's Annex, including those related to Syrian-origin petroleum and petroleum products. According to a guidance document issued by OFAC on May 28, 2025, examples of authorized transactions under GL 25 include, but are not limited to: telecommunications-related services, power-grid infrastructure rehabilitation and other energy-related services, healthcare-related services, education-related services, agricultural-related services, civil aviation and other transportation services, construction-related services, water and waste management-related services, and financial and investment services. U.S. financial institutions are now authorized to process transactions for any of the activities authorized by GL 25, and U.S. persons are authorized to provide support to the new government of Syria.
Limitations
Although relief afforded by the recent measures is broad, sanctions remain in place with respect to Syria. It is critical that entities seeking to do business in Syria under the new relief remain aware of these limitations:
- GL 25 does not authorize transactions and dealings with parties on the SDN List who are not among the 28 entities identified in the Annex to GL 25. Therefore, the vast majority of blocked persons remain blocked and cannot be parties to a transaction. It will thus remain necessary for companies to continue checking the SDN List, as well as ownership information of any counterparties to ensure that they are not 50% or more owned by any sanctioned parties.
- GL 25 does not authorize the unblocking of property or interests in property that were blocked as of May 22, 2025. Therefore, U.S. entities, including financial institutions, may not unfreeze property or interests in property blocked under the SySR. Doing so would require further sanctions relief, or a specific license from OFAC.
- GL 25 does not authorize any transactions for or on behalf of embargoed destinations beyond Syria. More specifically, for example, it does not authorize transactions for or on behalf of the governments of Russia, Iran, or North Korea, or the transfer or provision of goods, technology, software, funds, financing, or services to or from Russia, Iran, or North Korea. Therefore, although new investments may now be made in Syria, they may not be made on behalf of these three countries or any other embargoed destinations.
- GL 25 does not impact export controls that prohibit the export or reexport of U.S.-regulated dual-use items to Syria. Nearly all items subject to the Export Administration Regulations (including basic EAR99 items) require a license to be sent to Syria. Further action from the U.S. Department of Commerce will be necessary to ease these export control restrictions.
- Syria remains a designated "state sponsor of international terrorism" under Section 40(d) of the Arms Export Control Act, prohibiting sales of arms and related goods and services. Thus, restrictions under the International Traffic in Arms Regulations (ITAR) remain in place. Further action from the executive branch will be required to lift this designation.
- Hay'at Tahrir al-Sham (HTS), which led the rebel coalition that overthrew President Assad, remains on the Department of State's list of Foreign Terrorist Organizations (FTO). The current president of Syria, President al-Sharaa, was the leader of HTS, and is himself designated as a Specially Designated Global Terrorist. Although GL 25 authorizes engagement with the new Syrian government, U.S. law prohibits the knowing provision of "material support or resources to a foreign terrorist organization" or any attempt or conspiracy to do so. See 18 U.S.C. § 2339B. As of now, this includes HTS. Although President al-Sharaa's government announced HTS' dissolution in January 2025, an FTO must be formally delisted by the Department of State before restrictions are removed. Therefore, until it is removed from the FTO list, there remains a possibility that providing aid to HTS risks criminal exposure.
Finally, none of GL 25, the Caesar Act waiver, or FinCEN's announcement formally lifts any sanction — the measures merely authorize otherwise prohibited actions while the Trump administration assesses Syria's development and progress on a number of issues important to the United States. Treasury's press release clarifies that relief is meant to support a Syria "that is stable, unified, and at peace with itself and its neighbors," and is contingent on the country not offering "a safe haven for terrorist organizations" and ensuring "the security of its religious and ethnic minorities." GL 25, the Caesar Act waiver, and FinCEN's exceptive relief can be revoked at any time, should Syria's government fail to live up to the Trump administration's expectations.
Conclusion
The Trump administration is hopeful that Syria's fledgling government under President al-Sharaa will unite the country, uphold its promise to root out terrorist groups, and respect the human rights of all its citizens. The relief measures by the U.S., in addition to those implemented by the EU and U.K., will allow U.S. and international investment in Syria, potentially providing President al-Sharaa and his government with the boost they need to jumpstart Syria's economy. Parties seeking to do business in Syria in light of this relief must ensure compliance with the limitations above and should consider protections — for instance, in the form of contractual exit clauses — to account for the risk that sanctions may be reimposed in the future.
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