On May 23, 2025, several US government agencies took major steps to suspend sanctions on Syria. These developments include (i) the US Treasury Department’s Office of Foreign Assets Control (OFAC) suspended many primary sanctions on Syria; (ii) the US State Department issued a 180-day waiver of mandatory secondary sanctions under the Caesar Civilian Protection Act of 2019 (the Caesar Act); and (iii) the US Treasury Department’s Financial Crimes Enforcement Network (FinCEN) authorized financial institutions to open and maintain correspondent accounts for the Commercial Bank of Syria.
The US steps to date, however, do not relax US export controls on Syria or relieve companies of their reporting obligations under Section 13(r) of the Securities Exchange Act of 1934. The US Commerce Department is expected to ease US export controls on Syria in the “fairly near future,” and as soon as the coming weeks.
The EU and UK have gone even further to lift (rather than suspend) most sanctions on Syria. On May 28, 2025, the EU removed most of its sanctions and export controls on Syria, including those targeting Syria’s banking, energy, and trade sectors. On March 6 and April 24, 2025, the UK lifted the majority of its sanctions on Syria, including asset freeze sanctions and trade sanctions targeting Syria’s government and the country’s banking, energy and aviation sectors. Certain EU and UK sanctions on Syria remain in place, however, including asset-freeze listings relating to the former Assad regime and ongoing counterterrorism sanctions against Hay’at Tahrir al-Sham (HTS).
The US, EU, and UK’s significant shift on Syria is intended to facilitate new investment and commercial opportunities in Syria. Companies considering business related to Syria may presently find both opportunities and challenges, while continued lifting of sanctions and export controls on Syria are expected to be on the way.
OFAC suspends US primary sanctions on Syria
OFAC’s GL25 generally authorizes transactions related to Syria, the Syrian government, and the SDNs listed in the Annex to GL25. GL25, however, does not authorize dealings with other SDNs, unblocking of blocked property, or dealings that are otherwise prohibited related to Russia, Iran, North Korea, or any other sanctions program.
As stated in OFAC’s fact sheet, these newly authorized transactions include dealings related to (i) services to people and companies in Syria; (ii) new investment in Syria; (iii) petroleum and petroleum products from Syria; (iv) the Syrian government as in existence on or after May 13, 2025; and (v) blocked persons listed in the Annex to GL25, even where such persons were blocked under non-Syrian sanctions programs.
From a due diligence and enforcement perspective, potential past violations of the US sanctions on Syria are likely to remain relevant to companies and OFAC. Note that this may remain the case for some time because the statute of limitations for sanctions violations extends back to April 24, 2019. For example, in the transactional context, companies and financial institutions might continue to include Syria in the definition of comprehensively sanctioned territories and conduct due diligence on potential breaches of US sanctions on Syria, even where such conduct occurred prior to the issuance of GL25.
Additionally, consistent with OFAC FAQs, the OFAC fact sheet on Syria states that GL25 effectively suspends secondary sanctions risks for non-US persons “engaging in activities or facilitating transactions or payments for such activities that would be authorized for US persons pursuant to GL25.”
GL25 does not have an expiration date. OFAC could amend or terminate it at any time, however, which could result in the reactivation of all US primary sanctions on Syria. In the long-term and in order to make the sanctions relief permanent, the Syrian government must take certain steps: (i) removing “Palestinian terror groups” from Syria; (ii) taking custody of detention facilities housing Islamic State fighters; (iii) moving forward on absorbing US-backed Kurdish forces into the Syrian army; (iv) joining the Abraham Accords; and (v) demonstrating that it has destroyed the previous government’s chemical weapons.
US export controls and Section 13(r) reporting requirements remain
OFAC states that GL25 does not suspend compliance with any other federal laws or requirements, including export controls under the International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR).
Export control restrictions on Syria remain for the time being and it could take years before they are lifted entirely. In October 2017, OFAC removed sanctions on Sudan, but BIS did not move Sudan from Country Group E:1 (terrorist supporting countries) to Country Group B (a much more permissive category) until January 2021. However, it is expected that US export controls on Syria may be eased on a relatively expedited timeline relative to Sudan. Reportedly, US export controls on Syria may be lifted in the “fairly near future.”
Additionally, publicly traded companies are still required to disclose activities (and activities of their affiliates) to the US Securities & Exchange Commission (SEC) covered under Section 13(r) of the Securities Exchange Act of 1934. Section 13(r) generally requires disclosures for certain Iran-related activities. For Syria, Section 13(r) might continue to be relevant because it also requires reporting transactions with persons in Syria blocked under Executive Order 13224 (Global Terrorism Sanctions Regulations, i.e., SDGT) or Executive Order 13382 (Weapons of Mass Destruction Proliferators Sanctions Regulations, i.e., NPWMD), several of which are included in the Annex to GL25.
US State Department temporarily waives secondary sanctions under Caesar Act
The US State Department suspended the secondary sanctions under the Caesar Act for 180 days. The Caesar Act requires the imposition of secondary sanctions on non-US persons that knowingly conduct certain “significant” transactions, including dealings related to the Syrian government, persons sanctioned under the Syria program, or specified goods or services related to Syria (e.g., military aircraft parts, petroleum). The US State Department action, however, does not suspend US secondary sanctions on persons in Syria targeted by other US sanctions programs that carry US secondary sanctions risk, such as US sanctions targeting Iran and Hezbollah.
Under Section 7432(b)(1) of the Caesar Act, the US State Department has the authority to waive the application of Caesar Act sanctions that would otherwise be required under Section 7412. This waiver is valid for renewable periods of up to 180 days each. The US State Department must continually renew the 180-day waiver (which currently will expire on November 19, 2025), unless the Caesar Act is amended or repealed by Congress. Additionally, a bipartisan-sponsored bill, HR 3941, has been introduced in Congress to repeal the Caesar Act. The bill is not yet law, and it is not clear if or when it will become law.
FinCEN actions to enable Syrian banking
FinCEN’s actions lift certain restrictions imposed by Section 311 of the USA PATRIOT Act, which otherwise would have limited capital flow into Syria by prohibiting covered financial institutions from opening and maintaining correspondent accounts for or on behalf of the Commercial Bank of Syria. FinCEN’s actions enable banking in Syria, which supplements OFAC’s action because it helps US persons engage in the transactions authorized under GL25. However, these actions do not lift covered financial institutions’ money laundering-related due diligence obligations under Section 312 of the USA PATRIOT Act.
EU lifts most sanctions on Syria
On May 20, 2025, the EU announced its political decision to lift most economic sanctions on Syria—including its restrictions against the Syrian Central Bank.
Subsequently, on May 27, 2025, the EU issued two regulations, Regulation 2025/1098 and Regulation 2025/1094, that lifted the majority of the EU’s economic sanctions against Syria, as part of a broader policy of supporting Syria’s economic recovery and contributing to greater stability in the region after the fall of the Assad regime. The EU also removed key asset freeze listings (24 in total), including major financial institutions such as the Central Bank of Syria and the Commercial Bank of Syria, as well as companies operating in key sectors for Syria’s economic recovery, including the petroleum sector. Delisted entities include Syria Trading Oil Company (Sytrol), General Petroleum Corporation (GPC), and the Al Furat Petroleum Company.
Additionally, the EU also removed a wide range of trade restrictions, including measures related to the export and import of crude oil and petroleum products, jet fuel and fuel additives (which had already been suspended as of February 24, 2025). It also repealed export and import restrictions on luxury goods, gold, precious metals and diamonds, as well as restrictions on participating in infrastructure projects.
Certain EU sanctions, however, remain in place, including some security-related restrictions, as well as asset freeze listings related to the former Assad regime and ongoing counterterrorism sanctions against HTS and the current interim president of Syria, Ahmed al-Sharaa. Dealings with the Syrian government are generally not prohibited under EU sanctions, however, despite al-Sharaa continuing to be targeted by EU sanctions. The EU has indicated that it may reconsider the listings of HTS and al-Sharaa if the UN Security Council decides to lift its terrorist designations on HTS and al-Sharaa, which currently remain in place.
UK terminates majority of its sanctions on Syria
The UK, like the EU, has partially lifted its Syria-related sanctions, including revoking most sectoral and financial sanctions and lifting several asset freezes. Notably, on April 24, 2025, the UK announced a “Plan for Change” on Syria, including removing restrictions on financial services and energy production in Syria.
The UK sanctions that remain in place include (i) asset freeze sanctions against individuals associated with the Assad regime or connected to terrorist groups; (ii) trade sanctions on military goods and goods and technology used for internal repression; (iii) other strategic trade sanctions on gold, precious metals and luxury goods; and (iv) prohibitions on trade in certain bonds issued by the Assad regime.
Additionally, HTS remains a Proscribed Terrorist Organisation under UK counter-terrorism laws, such that it is prohibited to make funds available to HTS or for its benefit. Given that a number of officials in the Syrian interim government, including its Interim President, were prominent members of HTS, the distinction between the new government and HTS requires careful consideration under UK sanctions as matters continue to develop.
Conclusion: opportunities and challenges for business with Syria
The US, EU, and UK have dramatically shifted sanctions and trade policy on Syria. The trend remains toward further relaxation of restrictions on business with Syria, assuming the new Syrian government does not backslide. For example, US Treasury Secretary Bessent stated that these changes are intended “to encourage new investment into Syria.” Accordingly, companies are now considering whether to do business related to Syria that has not been on the table for 14 years. Careful consideration should be given to ensure that business related to Syria is lawful, which for some companies might not be the case until there is further lifting of sanctions and export control restrictions.
