Overview
On May 23, 2025, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) provided immediate sanctions relief for Syria. That action came on the same day as relief granted by the US Department of State and Treasury’s Financial Crimes Enforcement Network (FinCEN). The announcements came a week after President Trump met with interim Syrian President Ahmad al-Sharaa in Saudi Arabia, where he discussed lifting sanctions to give Syria “a fresh start.”
Background and Overview
The US government initially imposed sanctions on Syria in 2011 in response to the abuses of Bashar al-Assad’s regime against Syrian civilians and its support for terrorist organizations in the region. The sanctions relief announced on May 23 comes in the form of Syria General License 25 (GL 25), which allows new investment and private sector activity in Syria, primarily through:
- Authorizing all transactions otherwise prohibited by the Syrian Sanctions Regulations, including transactions with the new Syrian government and certain Specially Designated Nationals (SDNs) identified in an Annex to GL 25, as well as any entities in which such SDNs own a 50 percent or greater interest, directly or indirectly;
- Allowing the export or reexport of services from the US or by US persons to Syria, including financial services;
- Permitting new investment in Syria; and
- Permitting transactions related to Syrian-origin petroleum and petroleum products.
Although GL 25 effectively lifts sanctions on Syria, it contains a few important restrictions. First, any transactions that benefit Russia, Iran, or North Korea – key supporters of the former Assad regime – continue to be prohibited. Also, transactions involving any SDNs not listed in the Annex to GL 25 (or any entities in which one or more SDNs not listed in the Annex owns a 50 percent or greater interest, directly or indirectly) are not authorized. Immediately following the lifting of sanctions there are still over 500 Syria-based SDNs, so significant sanctions risks remain for any Syria-related activity. Finally, GL 25 does not permit the unblocking of property or interests in property blocked as of May 22, 2025. Additional information can be found in OFAC’s recently-issued guidance on its sanctions relief.
Other Laws and Regulations
In addition to GL 25, the US Department of State concurrently issued a 180-day waiver of mandatory Caesar Syria Civilian Protection Act (Caesar Act) sanctions to facilitate investment from US allies and partners in Syria. Under the Act, for renewable periods not to exceed 180 days, the President has the power to:
- Waive the application of almost any provision under the Act with respect to a foreign person, if the President certifies to the appropriate congressional committees that such a waiver is in line with US national security interests; and
- Suspend, in whole or in part, the imposition of sanctions otherwise required under the Act, if the President certifies to Congress that certain conditions, such as the cessation of attacks on civilians, have been met.
Moreover, consistent with GL 25, FinCEN has issued an exception to certain restrictions, thereby allowing US financial institutions to maintain correspondent accounts for, or on behalf of, the Commercial Bank of Syria.
Notably, the relief granted by the US government has not, to date, included a change to US export controls regulations. The Export Administration Regulations (EAR) currently require a license for the export to Syria of all items subject to the EAR, except for EAR99 food and medicine. Additional license exceptions applicable to Syria are limited. It is possible that these restrictions may be modified in the near future, but no such announcements have yet been made. Therefore, any entity – whether or not a US person – should remain mindful of US export controls in relation to the export of any goods, technology, or software to Syria.
Syria’s Commitment
In return for sanctions relief, the US announced that Syria must commit to protecting religious and ethnic minorities within its territory, refrain from serving as a safe haven for terrorist organizations, and work toward becoming a stable and peaceful country. Therefore, the Trump Administration stated that it will continue to monitor developments on the ground in Syria as it continues to assess the suspension of US sanctions on Syria.
Looking Ahead
Given that OFAC provided sanctions relief via a general license (rather than a repeal or amendment to the underlying regulations), it could revoke the general license at any time and without warning if the US government determines that the Syrian government has fallen short of the commitments made to the United States in the context of the granting of sanctions relief. The US government could also modify its approach to sanctions as Syria moves forward with its effort to rebuild the country and meet the commitments made to the US government, similar to the approach it has taken to dismantling other sanctions regimes, such as those targeting Sudan and Libya. This fact, coupled with the 180-day waiver of the restrictions imposed under the Caesar Act, suggests that the relief provided to Syria is for now best viewed as tentative.
It is, therefore, important that companies assess opportunities in Syria through a sanctions compliance lens. Moreover, sanctions relief provided by GL 25 does not relieve any person or entity from complying with other federal laws that continue to apply to Syria, such as export controls and certain laws targeting terrorist activity.
For more information on the above, please contact a member of our Economic Sanctions team.
