U.S. Eases Restrictions On Commercial Engagement With Syria

Last week, the U.S. Department of State rescinded Syria’s designation as a State Sponsor of Terrorism and removed Hay’at Tahrir al-Sham from its list of Specially Designated Global Terrorist organizations. The U.S. Department of the Treasury’s Office of Foreign Assets Control also removed the group from its Specially Designated Nationals and Blocked Persons List. These actions represent the latest step in broader U.S. efforts to ease sanctions and export-control restrictions that previously limited commercial engagement with Syria, with the intent of supporting the country’s economic recovery and reintegration into the global economy.

These measures build upon steps taken by the administration since June 2025, when Executive Order 14312 terminated the national emergency relating to Syria and directed agencies to unwind key elements of the longstanding Syria sanctions framework. Since that time, the United States has repealed the Caesar Syria Civilian Protection Act, revoked Hay’at Tahrir al-Sham’s (HTS) designation as a Foreign Terrorist Organization, delisted certain Syrian government officials, relaxed export control restrictions, and waived various Syria-related sanctions. The updated Tri-Seal Advisory issued by the Departments of State, Treasury, and Commerce states that the United States no longer imposes comprehensive sanctions on Syria and that U.S. sanctions generally no longer act as a barrier to most business activity involving Syria.

Continued Sanctions Relief

The updated Tri-Seal Advisory highlights several significant changes to the U.S. sanctions and export-control framework applicable to Syria since 2025. In addition to rescinding Syria’s State Sponsor of Terrorism designation and delisting HTS, Congress repealed the Caesar Act, eliminating the threat of mandatory sanctions on foreign persons supporting certain Syrian government or infrastructure-related activities. The United States has also waived certain restrictions under the Syria Accountability Act and the Chemical and Biological Weapons Control and Warfare Elimination Act, removing several limitations on exports, financial assistance, and commercial engagement with Syria. As a result, the legal framework governing activities involving Syria is substantially different from the comprehensive sanctions regime that existed prior to 2025.

The United States has also taken significant steps to relax Syria-related export controls. Commerce amended the Export Administration Regulations (EAR) in September 2025 to ease licensing requirements for certain exports to Syria, including specified U.S.-origin goods, software, technology, communications equipment, and civil aviation-related items. The updated Tri-Seal Advisory indicates that the U.S. government anticipates additional regulatory changes to the EAR, as well as anticipated amendments to the International Traffic in Arms Regulations.

Restrictions Remain in Place

Despite the additional relief provided by these latest actions, not all Syria-related restrictions have been eliminated. The updated Tri-Seal Advisory makes clear that list-based sanctions remain in effect against numerous individuals and entities, including Bashar al-Assad and his associates, human rights abusers, Captagon traffickers, actors connected to Syria’s prior proliferation activities, ISIS and al-Qaida affiliates, Iran and its proxies, and other designated parties. Transactions involving blocked persons remain prohibited for U.S. persons and may create sanctions exposure for non-U.S. persons. Notably, last week’s measures also included the designation of two individuals alleged to be supporting al-Qaida and Hurras al-Din, emphasizing that the United States intends to maintain sanctions pressure on terrorist organizations and related parties.

Implications for U.S. Businesses

Although the United States has largely dismantled its prior Syria sanctions framework, companies should continue to exercise due diligence when engaging in Syria-related transactions. While recent actions significantly expand opportunities for trade, investment, and financial activity involving Syria, restrictions relating to designated parties and certain controlled activities remain in place.