The US Commerce Department’s Bureau of Industry and Security (BIS) published a new rule, effective September 2, 2025, that significantly relaxes US export controls on Syria and eases licensing requirements for exports and reexports to Syria of items subject to the Export Administration Regulations (EAR). The rule implements the waiver of certain US export controls on Syria that was announced in Executive Order 14312 of June 30, 2025 (the Executive Order).
Pursuant to the new rule, many of the US export controls on Syria have effectively been rolled back. For the remaining restrictions, expanded license exceptions and favorable licensing policies will apply.
Note that the new rule does not fully terminate US export controls on Syria because certain items on the Commerce Control List (CCL) may not be covered by available license exceptions, and the arms embargo for ITAR-controlled defense articles remains in place. The new rule also does not appear to roll back deemed export restrictions on Syrian nationals (i.e., export licensing requirements for transfers of controlled items to Syrian nationals outside of Syria).
- Broad Authorization for EAR99 Items to Syria: In June, pursuant to the Executive Order, the United States waived the imposition of certain export controls on Syria under the Syria Accountability Act and Lebanese Sovereignty Restoration Act (SAA). The SAA generally prohibited the export of products of the United States (other than food and medicine) to Syria. BIS’s new rule implements the waiver by adding a license exception called “License Exception Syria Peace and Prosperity” (SPP). License Exception SPP authorizes exports of all items designated EAR99 to Syria without a license, unless exported for a prohibited end-use or to a restricted end-user, such as individuals and entities designated on OFAC’s SDN List.
- Expanded License Exceptions: The rule expands the applicability and scope of existing license exceptions for items included on the CCL. Many items on the CCL are newly eligible for export to Syria without a license. Such items must meet the requirements, some of which are Syria-specific, of the following license exceptions: Consumer Communications Devices (CCD); Aircraft, Vessels and Spacecraft (AVS); Temporary, imports, exports, reexports, and transfers (in-country) (TMP); Servicing and replacement of parts and equipment (RPL); Governments, international organizations, international inspections under the Chemical Weapons Convention, and the International Space Station (GOV); Technology and software—unrestricted (TSU); and Baggage (BAG).
- License Exceptions CCD and RPL newly apply to exports to Syria. License Exceptions AVS, TMP, GOV, and TSU already applied to certain Syria exports, however, the new rule expands the scope of these exceptions. For example, the scope of License Exception AVS has been expanded to include US-registered aircraft on temporary sojourn to Syria.
- Permissive Licensing Policy: License applications for exports to Syria had been subject to a general policy of denial. Under the new rule, however, BIS adopts a presumption of approval for commercial end uses “that support economic and business development in Syria or that support the Syrian people,” which includes “improvement or maintenance of telecommunications water supply and sanitation, power generation, aviation, or other civil services that support peace and prosperity in Syria without making a significant contribution to the military potential of Syria or the ability of Syria to support acts of international terrorism.”
- License applications for export to Syria of all other items on the CCL (i.e., those without such commercial end use) are subject to a case-by-case standard of review, unless a stricter standard applies. Additionally, the new licensing policy contemplates that BIS may grant export licenses for military or military end-use items on the CCL, subject to a statutorily required 30-day notice to Congress.
The new rule brings US export control policy for Syria more in line with current US sanctions policy on Syria. In June and July 2025, the United States permanently terminated the comprehensive Syria sanctions program. BIS’s new rule is the latest action in the US government’s commitment to ease trade restrictions on Syria following the overthrow of the Assad regime in December 2024. The relaxation of US export controls continues to pave the way for new investment and business opportunities related to Syria.
Our global sanctions and trade practice continues to monitor Syria-related developments under US, EU, and UK sanctions and trade regimes.
