U.S. Agencies Issue Tri-Seal Compliance Note On Sanctions And Export Controls Relief For Syria

Overview

On November 10, 2025, the U.S. Departments of the Treasury, Commerce, and State issued a Tri-Seal Compliance Note (the "Note") outlining the scope of recent U.S. sanctions and export controls relief for Syria. The Note follows President Trump's May 13 announcement of a policy shift toward supporting Syria's economic recovery and regional reintegration, culminating in the issuance of Executive Order ("E.O.") 14312 on June 30, 2025. We previously published a blog post on this topic on May 15, 2025.

The Note provides a comprehensive overview of the current U.S. sanctions and export control posture toward Syria, including the recent removal of sanctions, the suspension of the Caesar Act, and the easing of export licensing requirements for certain U.S.-origin goods and technologies, as detailed further below.

Key Developments

Termination of Comprehensive Sanctions

E.O. 14312 formally terminated the Syria sanctions program, which had been implemented by the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") under 31 C.F.R. part 542. A final rule removing the Syria Sanctions Regulations from the Code of Federal Regulations effective on August 26, 2025.

Suspension of Caesar Act Sanctions

On November 10, 2025, the Secretary of State suspended the imposition of sanctions under the Caesar Syria Civilian Protection Act of 2019 for 180 days. This suspension replaces the May 23 waiver and halts the imposition of Caesar Act sanctions, except for transactions involving the governments of Russia and Iran or the transfer of Russian or Iranian origin goods, technology, software, funds, financing, or services.

Export Controls Eased

On September 2, 2025, the Department of Commerce implemented a rule easing licensing requirements for dual-use exports to Syria. U.S.-origin goods, software, and technology with predominantly civilian uses, as well as specified consumer communications devices and certain civil aviation items, no longer require an export license. The rule also facilitates license approvals for exports supporting telecommunications infrastructure, sanitation, power generation, civil aviation, and other civil services.

Issuance of Syria General License 25

On May 23, 2025, OFAC issued General License ("GL") 25, authorizing U.S. persons, to the extent still necessary, to engage in transactions involving certain blocked persons related to Syria. This includes the provision of services to Syrian governing institutions, even where leadership remains designated. We previously posted a blog covering GL 25 in further detail on June 20, 2025.

Other Notable Sanctions and Licensing Developments

• On June 30, 2025, the President waived the application of the Syria Accountability and Lebanese Sovereignty Restoration Act with respect to certain items on the Commerce Control List.
• On July 8, 2025, the Secretary of State revoked the Foreign Terrorist Organization ("FTO") designation of al-Nusrah Front, also known as Hay'at Tahrir al-Sham.
• On July 20, 2025, the Secretary of State waived sanctions under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 related to foreign assistance, U.S. government credit, exports of specified goods and technology, and loans or credit from U.S. financial institutions to the Government of Syria.
• On November 7, 2025, the United States removed Muhammad al-Jawlani (Syrian President Ahmed al-Sharaa) and Syrian Interior Minister Anas Hasan Khattab from the Specially Designated Global Terrorist ("SDGT") list.

ContinuingRestrictions

While the United States has lifted comprehensive sanctions on Syria, significant restrictions remain in place targeting individuals and entities deemed to pose a threat to regional stability and U.S. national security interests. These include:

Designated Individuals and Entities

Following the Note, sanctions remain in effect against "the worst of the worst," including:

• Bashar al-Assad and his close associates
• Human rights abusers
• Captagon drug traffickers
• Individuals and entities involved in Syria's past weapons of mass destruction proliferation activities
• Affiliates of ISIS and Al-Qa'ida
• Iranian and Russian actors operating in Syria, including proxies designated under Executive Order 13894 ("Promoting Accountability for Assad and Regional Stabilization Sanctions") and other authorities.

State Sponsor of Terrorism ("SST") Designation

Syria remains designated as a SST. The U.S. government continues to review this designation, which imposes additional restrictions on foreign assistance, defense exports and sales, and certain financial transactions.

Export Licensing Requirements

Although many U.S. origin items for basic civilian use may now be exported to Syria without a license, most items on the Commerce Control List still require a license from the Department of Commerce. This includes sensitive dual-use technologies and items not covered by the September 2, 2025, export control easing rule.

Caesar Act Limitations

While the Caesar Syria Civilian Protection Act of 2019 has been suspended for 180 days as of November 10, 2025, the suspension does not apply to transactions involving the governments of Russia or Iran, or the transfer of Russian- or Iranian-origin goods, technology, software, funds, financing, or services.

Key Takeaways

The Note underscores the U.S. government's intent to encourage lawful reengagement with Syria by U.S. and foreign businesses, while maintaining pressure on malign actors. We note that the U.S. government retains authority under the International Emergency Economic Powers Act and the Export Control Reform Act of 2018 to reimpose or adjust controls as necessary to protect national security and foreign policy interests, and it remains possible for the current relief measures to be modified, narrowed, or revoked in response to future developments or policy shifts.

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