Highlights
- On June 30, 2025, President Donald Trump issued an Executive Order (the EO) terminating the U.S. government's Syria sanctions program and directing other actions that, if finalized, will revoke the vast majority of U.S. trade restrictions imposed on Syria by the U.S. government.
- The EO lifts in large part the majority of trade and investment restrictions on Syria by, among other things: 1) terminating and revoking the Syria Sanctions program as codified within the Syrian Sanctions Regulations; 2) removing 518 parties sanctioned under six different EOs underlying the sanctions program; and 3) directing actions that, if finalized, will effectively lift the most stringent aspects of the comprehensive export controls and other trade restrictions imposed on Syria.
- The Trump Administration is maintaining sanctions imposed on 139 individuals and entities associated with the former regime of Bashar al-Assad and other "destabilizing actors in the region" linked to ISIS and al-Qaida affiliates, as well as Iran and its proxies.
President Donald Trump issued an Executive Order (the EO) on June 30, 2025, terminating the U.S. government's Syria sanctions program and directing other actions that, if finalized, will revoke the vast majority of U.S. trade restrictions imposed on Syria by the U.S. government, effective July 1, 2025.
Background
As noted in a previous Holland & Knight alert, in response to the collapse of the regime led by Bashar al-Assad and efforts by the new government led by Ahmed al-Sharaa to cooperate with the United States on counter-terrorism efforts, the Trump Administration took substantial steps to relax economic sanctions imposed on Syria, including the issuing of General License 25 (GL 25) on May 23, 2025, and waiving certain sanctions under the Caesar Syria Civilian Protection Act of 2019 (the Caesar Act). However, even as these measures authorized U.S. persons to engage in many activities otherwise prohibited under the Syria sanctions program, significant restrictions on trade with Syria remained in effect, including blocking sanctions on numerous parties and comprehensive export control restrictions.
Impact of June 30 EO
Issued just over a month after GL 25 was published, the EO marks an end to one of the U.S. government's most comprehensive and restrictive sanctions programs and moves toward fully removing the stringent export controls restrictions on Syria.
In a press release, the U.S. Department of the Treasury Office of Foreign Assets Control (OFAC) explained that "[t]he circumstances that gave rise to OFAC's Syria sanctions program, related to the brutal former regime of Bashar al-Assad, have been transformed by developments over the past six months, including the positive actions taken by the new Syrian government under President Ahmed al-Sharaa."
With respect to U.S. sanctions, the EO:
- revokes six of the key EOs underlying the Syria Sanctions Regulations and terminates and the national emergency underlying these EOs
- removes from OFAC's List of Specially Designated Nationals (SDN) and Blocked Persons (SDN List) 518 individuals and entities designated under the Syria sanctions program
- directs the U.S. Secretary of State "to examine whether to suspend the imposition of some or all of the sanctions required under the Caesar Act"
With respect to U.S. export controls, the EO:
- waives certain export restrictions mandated by the Syria Accountability and Lebanese Sovereignty Restoration Act of 2003, which previously resulted in a license requirement for "any item" subject to the Export Administration Regulations (EAR) to Syria (with the exception of EAR99 food and medicine)
- waives the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991's (CBW Act) mandated restrictions on the export of any item subject to the EAR that is controlled for national security (NS) reasons, although this may not ultimately lead to the removal of a license requirement for NS-controlled items destined Syria
- directs the Secretary of State to "take all appropriate action" with respect to Syria's designation as a State Sponsor of Terrorism (SST), which, among other things, results in a license requirement on any item subject to the EAR that is controlled for anti-terrorism (AT) reasons
The EO also:
- waives restrictions on Syria related to foreign assistance, U.S. government credit or other financial assistance, and loans and credit from U.S. financial institutions imposed by the CBW Act
- directs the Secretary of State to "take all appropriate action" with respect to Hay'at Tahrir al-Sham's (HTS) designation as a Specially Designated Global Terrorist (SDGT) and Foreign Terrorist Organization (FTO), "as well as the designation of Abu Muhammad al Jawlani, commonly known as Ahmed al-Sharaa," as an SDGT
Remaining Issues
- President Trump has emphasized that while these measures aim to "give Syria a chance to rebuild and thrive," his administration will continue "to guard against all threats and monitor progress on key priorities," which include: "taking concrete steps toward normalizing ties with Israel, addressing foreign terrorists, deporting Palestinian terrorists and banning Palestinian terrorist groups, helping the United States prevent a resurgence of ISIS, and assuming responsibility for ISIS detention centers in northeast Syria."
- Concurrent with the termination of the Syria sanctions program, President Trump modified and expanded the national emergency declared in EO 13894 to maintain blocking sanctions on persons linked to the former regime of Bashar al-Assad and other "destabilizing actors in the region" linked to ISIS and al-Qaida affiliates, as well as Iran and its proxies. Accordingly, OFAC redesignated 133 individuals and entities affiliated with the previous Assad regime under EO 13894, as amended. An additional six other individuals and entities were redesignated under OFAC's Iran- and counterterrorism-related sanctions authorities.
- Notably, the full impact that these waivers and other directed actions will have on the applicable export controls restrictions that apply to Syria is not entirely clear yet, and there remain a few determinations that must be made official before many of these and other changes go into effect. It is also not clear whether certain export controls-related restrictions that apply to military end users (MEUs) or military intelligence end users (MIEUs) applicable to Syria may be adjusted based on these determinations. Furthermore, Syria's status as an SST as well as HTS and al-Sharaa's FTO and/or SDGT designations are still subject to "review" by the Secretary of State, suggesting some of these actions may not be final. Ultimately, given the various authorities and variables that inform certain restrictions, export license requirements likely will still apply to a significant number of items when destined for Syria, even after the most stringent export controls restrictions on Syria are lifted.
Compliance Considerations
While these measures mark a significant policy shift toward Syria, businesses looking to enter the Syrian market should still be cautious in conducting due diligence and be cognizant of several trade compliance issues, including the following:
- The Trump Administration's messaging around these measures indicates the potential for a reversal if the new Syrian government fails to make progress on its key priorities concerning counterterrorism and regional stability.
- Other sanctioned parties have a significant presence in Syria, including entities with links to Iran, Hezbollah and Russia, as well as the other parties in Syria whose SDN status will be maintained under a now-modified EO 13894. The prevalence of SDNs may present practical trade compliance risks, requiring careful due diligence and compliance measures.
- Although the sanctions imposed under the Caesar Act impact a smaller number of parties within Syria, these cannot be unilaterally revoked by the Trump Administration or extended beyond 180 days without congressional action.
- As noted above, the full impact that these measures and determinations may have on export controls restrictions under the EAR is still unclear, meaning businesses will still need to carefully consider what license requirements apply to different items they intend to export, reexport or transfer to end users in Syria.
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.
