On June 30 and July 7, 2025, President Trump issued Executive Order 14312 permanently revoking US sanctions on Syria by rescinding the Syrian Sanctions Regulations (31 CFR Part 542; the SySR) and the US State Department revoked the Foreign Terrorist Organization (FTO) designation of Hay’at Tahrir al-Sham (HTS). Pursuant to this action, the United States’ comprehensive Syria sanctions program no longer exists. The Executive Order also creates a new Assad-focused sanctions program, effective July 1, 2025.
Note that US export controls on Syria remain largely intact for now. The Executive Order, however, waives certain export controls relating to the export of national security-sensitive goods and technology under the Syria Accountability Act and Lebanese Sovereignty Restoration Act (Syria Accountability Act) and the Chemical and Biological Weapons Act (CBW Act).
- Delisting of Syrian SDNs: The Executive Order removes from OFAC’s SDN List 518 individuals and entities designated solely pursuant to the SySR, including all Syrian financial institutions. More than 100 Syrian individuals and entities remain on the SDN List, now designated under a new sanctions program under the title Promoting Accountability for Assad and Regional Stabilization Sanctions (PAARSS) program.
- Syrian financial institutions: The Executive Order removes the prohibition on providing financial services to Syria, processing payments and conducting transactions with Syrian banks, and conducting transactions with the new Syrian government, as long as none of the parties are still on the SDN List after the Executive Order.
- Terrorism designations: In response to the Executive Order, the US State Department removed the FTO designation of HTS and al-Nusrah Front, effective July 8, 2025. HTS and its leader, Abu Muhammad al-Jawlani (a.k.a. Ahmed al-Sharaa), however, remain on the SDN List, pending a review of these designations as directed by Executive Order 14312. Additionally, the Executive Order instructs the US State Department to assess whether to remove Syria’s designation as a State Sponsor of Terrorism, which is a prerequisite for lifting certain restrictions.
- Export controls: The Executive Order waives certain requirement to impose certain export controls under the Syria Accountability Act and the CBW Act. The Executive Order does not lift US export controls on Syria imposed by the US Commerce Department’s Bureau of Industry and Security (BIS). These export controls, however, are expected to be relaxed soon.
- New sanctions program targeting certain Syrian persons: Certain limited US sanctions on Syria remain under a new program called PAARSS. Under the new sanctions program, OFAC has designated 139 individuals and entities associated with the previous Syrian government, including Bashar al-Assad and his associates, human rights violators and drug traffickers, and individuals connected to Syria’s past proliferation activities, ISIS and Al-Qa’ida affiliates, and Iran and its proxies.
- Caesar Act: The Executive Order directs the US State Department to examine whether to suspend some or all of the mandatory secondary sanctions under the Caesar Act and report findings to Congress within 30 days of its determination. This follows the US State Department’s May 23, 2025, 180-day waiver of mandatory secondary sanctions under the Caesar Act.
These developments are the latest in the US government’s commitment to ease sanctions on Syria following the overthrow of the Assad regime in December 2024. They are a dramatic shift in US sanctions and trade policy on Syria, and they represent a potential opportunity for companies to do business related to Syria that has not been on the table for many years.
Our global sanctions and trade practice continues to monitor Syria-related developments in the EU and UK.
