U.S. Agencies Clarify Syria Sanctions Removals

Washington, D.C. (November 26, 2025) - On November 10, 2025, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) published the Tri-Seal Advisory. The Tri-Seal Advisory is a coordinated effort between the U.S. Department of the Treasury, the U.S. Department of State, and the U.S. Department of Commerce to offer those seeking to transact with Syria certainty regarding permissible trade guidance. The Tri-Seal Advisory clarifies that:

• The United States no longer imposes comprehensive sanctions on Syria;
• The Caesar Act is suspended, except for sanctionable transactions with Russia and Iran;
• The transfer of most basic civilian use of U.S.-origin goods, as well as software and technology, to or within Syria is permitted without a license.

The Tri-Seal Advisory also confirms the following restrictions:

• Sanctions remain on "the worst of the worst": Bashar al-Assad and his associates, human rights abusers, captagon drug traffickers, and other destabilizing regional actors.
• The U.S. Government continues to review Syria's State Sponsor of Terrorism (SST) designation.
• Most Commerce Control List items going to Syria still require a U.S. export license.

Also on November 10, 2025, Secretary of State Marco Rubio issued a press statement announcing a six-month waiver of the Caesar Act Sanctions. The Caesar Act placed statutory sanctions on Syria, but permits the executive branch to waive them; however, only Congress can permanently repeal these sanctions. The Caesar Act (full name Caesar Syria Civilian Protection Act), was imposed during the rule of former Syrian ruler Bashar al-Assad, and restricted transactions with the Syrian government and exports of military goods and items used in Syrian human rights violations; it also blocked financial transactions. Congress is currently determining whether the Caesar Act will be fully repealed, and if so, it is likely to be with the passing of the proposed National Defense Authorization Act of 2025.

Syria was among the most heavily sanctioned countries by the United States. On June 30, 2025, President Trump committed to the revocation of all U.S. Sanctions on Syria. Various U.S. agencies have taken key executive actions this year such as:

• Syria General License (GL) 25 (May 23, 2025): which Authorizes U.S. persons to engage in transactions with certain blocked persons related to Syria and allows provision of services to Syrian governing institutions even if leadership is designated. See our previous alert here.
• Syria Accountability Act Waiver (June 30, 2025): Waives restrictions on certain items on the Commerce Control List and facilitates commercial activity and economic development.
• FTO Designation Revocation (July 8, 2025): Al-Nusrah Front (Hay'at Tahrir al-Sham) removed from Foreign Terrorist Organization list. See our previous alert here.
• CBW Act Sanctions Waiver (Effective July 20,2025): Waives restrictions on foreign assistance, U.S. government credit, exports of specified goods, and loans to Syria.
• Export Controls Eased (September 2, 2025): Reduced licensing requirements for dual-use exports with civilian applications and facilitates exports for telecommunications, sanitation, power generation, civil aviation, and other civil services.
• SDGT Designations Removed (November 7, 2025): Syrian President Ahmed al-Sharaa and Syrian Interior Minister Anas Hasan Khattab removed from SDGT list.
• Caesar Act Suspension (November 10, 2025): Suspends most Caesar Act sanctions for 180 days. Exceptions: transactions involving Russia, Iran, or transfer of Russian/Iranian-origin goods or services.

Key Takeaway

Regulations concerning Syria are changing at a rapid pace, and these sanctions removals offer investors access to a new market eager to engage with the world. Further, permanent waivers and suspensions of statutory sanctions require Congressional action. Accordingly, those seeking to conduct business in Syria should remain alert, ready to adapt their business strategies to this evolving regulatory landscape.

Lewis Brisbois's attorneys are actively engaged in the wide range of legal issues in this area and are advising clients on managing legal and business risk as events continue to develop at an accelerated pace. For more information, contact the author or editor of this alert.Visit our Ukraine Conflict, International Trade, Export, Import and Investment Controls & National Security Practicepage for additional alerts in this area.

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