Syria Sanctions Rollback: U.S., UK, and EU Updates in a Global Context

Following the collapse of the Assad regime in December 2024, the United States, the European Union, and the United Kingdom have each taken steps to relax or lift sanctions against Syria. Earlier this week, the U.S. took steps to formally lift the majority of sanctions remaining on Syria. While these measures are intended to promote engagement with the Syrian economy, several restrictions remain in place. Below we provide responses to commonly asked questions, which reflect the key considerations that businesses should be aware of when reentering the Syrian market.

1. What has happened with respect to sanctions on Syria?

United States: On Monday, June 30, 2025, President Donald Trump signed an executive order (the June 30 EO) formally terminating the Syria Sanctions Program.¹ The June 30 EO rescinds several executive orders that previously authorized sanctions against Syria and certain Syrian persons that formed the foundation of the Syria Sanctions Program. Persons blocked exclusively pursuant to the rescinded orders were removed from the U.S. Department of the Treasury Office of Foreign Assets Control (OFAC) List of Specially Designated Nationals and Blocked Persons (SDN List), and all property and interests in property of those persons are now unblocked. The Trump administration also issued through the June 30 EO certain waivers that support the relaxation of export controls on Syria.

The June 30 EO follows President Trump’s May 13, 2025, announcement that he would be ordering the cessation of sanctions against Syria. In the interim, OFAC had issued General License (GL) 25 on May 23, 2025, which had effectively lifted most U.S. sanctions restrictions on Syria by authorizing transactions previously prohibited under several sanctions regimes.²

Following the issuance of the June 30 EO, OFAC announced that it would implement the directives in the order, including by removing the Syrian Sanctions Regulations from the Code of Federal Regulations.

The June 30 EO also directs the U.S. Department of State to evaluate suspending secondary sanctions under the Caesar Syria Civilian Protection Act, either in whole or in part, if certain criteria are met. The Department of State had previously issued a temporary waiver of mandatory secondary sanctions under the Caesar Syria Civilian Protection Act, which was intended to facilitate investment in key sectors of the Syrian economy by non-U.S. persons. The June 30 EO also directs the Department of State to reconsider Syria’s designation as a State Sponsor of Terrorism.

European Union: On February 24, 2025, the EU suspended the application of certain sanctions restrictions (including, e.g., in the banking, energy, and transport sectors) targeting Syria to support political transition and economic recovery. As from May 29, 2025, the EU lifted most sanctions targeting Syria (including those suspended since February 2025).

United Kingdom: On February 12, 2025, the UK Office of Financial Sanctions Implementation issued a GL allowing for payments to be made to support humanitarian delivery. On March 6, 2025, the UK delisted 24 entities (meaning they are no longer subject to sanctions), including many state-owned financial institutions, energy companies, and Syrian Arab Airlines. On April 24, 2025, a second wave of delisting removed Syrian government and media entities. On April 25, 2025, the UK Syria (Sanctions) (EU Exit) (Amendment) Regulations 2025 (the UK Amendment Regulations) came into force.³

2. Which sectors of the Syrian economy are now permitted for investment?

United States: Effectively all sectors of the Syrian economy are now permitted for investment. Additionally, all Syrian financial institutions, including the Central Bank of Syria, have been removed from the SDN list.⁴ Thus, effective July 1, 2025, U.S. persons are permitted to provide financial services to Syria, process payments on behalf of third-country financial institutions involving Syrian financial institutions, or conduct transactions with the new Government of Syria and Syrian financial institutions.

Additionally, because GL 25 authorized transactions prohibited under the Syrian Sanctions Regulations as well as transactions involving specified persons otherwise prohibited by certain other sanctions programs, GL 25 remains in effect and may be relied on as needed to the extent that transactions are still prohibited.⁵

European Union: Effectively all sectors of the Syrian economy are now permitted for investment. The EU lifted most sanctions, including prohibitions on investments in the crude oil sector; construction/installation of new electricity production power plants; and opening new bank accounts, establishing new correspondent banking relationships, or establishing new joint-ventures with Syrian credit/financial institutions or establishing business presence in Syria. The EU delisted 24 Syrian entities, including the Central Bank (as regards its assets located abroad as of February 27, 2012) and the various Syrian commercial banks that were previously targeted. The EU also lifted a wide range of export and import bans, such as the import ban on crude oil or petroleum products, and export bans on oil and gas-related equipment and technology, jet fuel and fuel additives, equipment and technology used in the construction or installation of new electricity production power plants in Syria, and certain luxury goods. Finally, the EU lifted the prohibition on transporting crude oil/petroleum products originating in/exported from Syria to any other country and allowed acceptance of Syrian Arab Airlines flights and cargo flights operated by Syrian carriers.

United Kingdom: Effectively all sectors of the Syrian economy are now permitted for investment. The UK Amendment Regulations removed the majority of the UK’s sectoral measures in place on the financial and banking sector (including banks within the scope of UK sanctions now being permitted to open bank accounts at, and conduct correspondent banking with, Syrian banks); the insurance sector; the crude oil and petroleum products sector (including aviation fuel and aviation fuel additives); and the electricity production sector.

3. Is it permitted to engage with the Syrian government?

United States: Yes, U.S. persons are permitted to engage in transactions involving the new Government of Syria as long as the Government of Syria does not involve sanctioned persons not also listed on GL 25. This pertains only to the new Syrian government and does not authorize transactions involving Bashar al-Assad, his enablers, or parties that continue to be listed as sanctioned parties.

European Union: Yes, persons subject to EU sanctions jurisdiction are permitted to engage in transactions involved the new Government of Syria subject to confirming no other involvement of designated persons or restricted activities. The Ministry of Defence and Ministry of Interior remain designated, but national competent authorities of EU member states may license interactions with them, provided it is necessary for the cooperation between those Syrian ministries and EU governmental entities the areas of reconstruction, capacity-building, counterterrorism, and migration.

United Kingdom: Yes, persons subject to UK sanctions jurisdiction are permitted to engage in transactions involved the new Government of Syria subject to confirming no other involvement of designated persons or restricted activities. The UK has taken steps to facilitate interaction with the new Government of Syria. For example, the UK has delisted the following Syrian security and defense government entities: the Ministries of Defense and Interior, General Intelligence Directorate, Air Force Intelligence Agency, Political Security Directorate, Syrian National Security Bureau, Military Intelligence Directorate, Army Supply Bureau.

4. What steps should be taken to benefit from the sanctions’ relaxation?

United States: Parties may take advantage of the relaxation in sanctions without further outreach or application to the U.S. government. However, parties should be aware of continued obligations under U.S. export controls, including license requirements, which are further discussed below. In addition, there are several groups of persons in Syria that continue to be sanctioned by the U.S. government. The recent actions do not authorize dealings with sanctioned persons.

European Union: The EU lifted the majority of sanctions targeting Syria by making the necessary legislative changes to the EU Syria sanctions program (Council Regulation (EU) No 36/2012 of January 18, 2012). As such, no additional steps are required to benefit from the sanctions’ relaxation. Parties are still expected to engage with national competent authorities of EU member states in relation to the licensing of any activity that remains prohibited.

United Kingdom: As in the EU, the UK Amendment Regulations modified the Syria (Sanctions) (EU Exit) Regulations 2019, meaning that no additional steps are required to benefit from the sanctions’ relaxation.

5. What is still prohibited or restricted with respect to Syria?

United States: The administration issued waivers in the June 30 EO that support the relaxation of export controls, specifically by waiving the application of the underlying statute that previously required the imposition of restrictive export controls on Syria. However, as of the date of this alert, the U.S. Department of Commerce Bureau of Industry and Security (BIS) has not yet removed restrictive U.S. export controls on Syria. Until such time as BIS removes the restrictive controls on Syria, it is still virtually prohibited to, directly or indirectly, export or reexport any goods, software, or technology subject to the U.S. Export Administration Regulations (EAR) to Syria absent a license (other than certain food and medicine).⁶ License requests for exports and reexports to Syria historically have been reviewed under a general policy of denial.

With the revocation of the Syria-sanctions-related executive orders, it means that all persons and entities that were previously sanctioned under those orders are now unblocked. However, the administration wanted to make sure some previously sanctioned persons remained sanctioned (in particular, officials of the former Assad regime who have not demonstrated support for Syria’s new government, those who provided material support to the former Assad regime, persons involved in the trade and distribution of captagon, companies owned by individuals sanctioned in today’s action, and those who have acted on their behalf). To this end, OFAC redesignated that subset of persons, as well as certain additional persons, under a different authority, specifically Executive Order 13894. Executive Order 13894 remains in effect (and through the June 30 EO, its scope was expanded), so persons redesignated under this authority remain blocked. Persons subject to U.S. sanctions jurisdiction should be mindful of these restrictions when reengaging with Syria, as it would still be prohibited to engage in dealings involving such sanctioned persons.

Additionally, while the June 30 EO directs the Department of State to review Syria’s designation as a State Sponsor of Terror, that designation and its associated restrictions remain in effect.

Neither the June 30 EO nor GL 25 authorizes transactions or dealings (i) for or on behalf of the Russian, Iranian, and North Korean governments or that involve the provision of goods, services, funds, and finances to and from Iran, Russia, or North Korea; (ii) in blocked property (i.e., property of persons who remain blocked); or (iii) involving sanctioned parties not otherwise listed in, or owned by parties listed in, the GL 25 Annex.

European Union: The EU still maintains a number of asset-freezing measures on persons and entities related to the Assad regime and/or targeting persons or entities responsible for human rights violations. The EU also maintains a number of security-based prohibitions, including, for example, an export ban/licensing requirement on certain internal repressions and related items and technology, an export ban on certain monitoring or interception items (including software and technology) and the provision of monitoring/interception services, as well as an import ban on Syrian military goods and cultural property.

United Kingdom: The UK still maintains asset-freezing measures on around 310 individuals and 38 entities, so any dealings in Syria should still be treated as high risk for UK sanctions screening purposes. Sale or purchase of Assad regime bonds involving a Syrian credit or financial institution, or a person connected to such institution, remains prohibited. This applies to bonds guaranteed by the Assad regime and issued between January 19, 2012, and December 8, 2024. Trade in the following (including funding or financing such trade) remains prohibited: military goods and technology; goods and technology relating to chemical and biological weapons; interception and monitoring goods and technology; internal repression goods and technology; gold, precious metals, or diamonds; luxury goods; and the provision of interception and monitoring services.

6. What can we expect in terms of further sanctions relaxation?

United States: The administration has effectively lifted the vast majority of sanctions on Syria; however, OFAC remains committed to enforcing sanctions on Assad, terrorist groups, and other persons connected to harmful activities in Syria. Numerous individuals and entities that engaged in these harmful activities remain on or have been added to OFAC’s SDN list, and we do not anticipate OFAC’s relaxing its stance toward these individuals and entities.

As discussed above, as of the date of this alert, while the administration has removed many of the statutory barriers to the relaxation of export controls, Syria still remains subject to heightened restrictions under U.S. export controls. BIS officials have stated the intention to relax Syria-related export controls in the coming weeks or months. However, the details of these efforts, as well as the timing of such actions, remain unknown. Parties interested in reengaging in Syria should continue to monitor this space for updates. Notably, the waiver of export controls restrictions in the June 30 EO does not extend to items controlled on the U.S. Munitions List.

European Union: With respect to the (limited) number of restrictions still in place, it is unlikely that the EU would lift those restrictions in the near term; to the contrary, on June 23, 2025, the EU designated additional five persons responsible for serious human rights violations in Syria pursuant to the EU Global Human Rights sanctions program.

United Kingdom: The majority of UK sectoral sanctions measures have now been lifted. As some measures remain, there is still scope for further relaxation on the UK side, but there have been no indications from the UK government as to whether it is actively considering this. In addition, the UK Amendment Regulations provided new powers to the UK government to allow it to designate as sanctioned persons anyone who is or has been involved in the commission of, or the obstruction of an independent investigation into, a serious human rights violation or abuse in Syria; the commission of a violation of international humanitarian law in Syria; undermining democracy, the rule of law, and good governance in Syria; the obstruction of humanitarian assistance activity in Syria; any other action, policy or activity that threatens the peace, stability, or security of Syria.

7. What other considerations should businesses be aware of when reentering the Syrian market?

While certain actions involving Syria may now be permitted under U.S., EU, and/or UK sanctions regimes, many companies have made representations or other contractual commitments to third parties, such as financial institutions and insurers, stating that they will not do business involving Syria. These statements and representations are not necessarily qualified with respect to whether such activity would be in violation of U.S., EU, and/or UK sanctions. Therefore, even if a party can do business in Syria in compliance with the relevant sanctions, such business might nevertheless still be in violation of contractual commitments to third parties.

For companies with internal policies prohibiting any business transactions in Syria, they should consider whether to update their policies and other forward-looking contractual terms.

In addition, companies looking to enter the Syrian market will need to be mindful of the heightened risk of the imposition of new sanctions, particularly if the political situation worsens. Robust contractual provisions as to ongoing trade compliance are advisable, including provisions allowing for an efficient exit from the market in the event that the sanctions are ratcheted back up.

Finally, companies should comply with any applicable reporting requirements. For instance, transactions involving certain sanctioned parties can trigger disclosure requirements under U.S. securities regulations, even if those transactions are otherwise authorized. The EU also maintains a requirement to provide in advance certain customs-related information for all goods leaving the EU to Syria.

_______________________________________________________________________________________________________________________________________________

¹Executive Order, “Providing for the Revocation of Syria Sanctions” (June 30, 2025), https://www.whitehouse.gov/presidential-actions/2025/06/providing-for-the-revocation-of-syria-sanctions/.

²See OFAC, General License No. 25 (May 23, 2025) (GL 25), https://ofac.treasury.gov/media/934306/download?inline.

³https://www.legislation.gov.uk/uksi/2025/507/contents/made.

⁴See OFAC, Frequently Asked Question (FAQ) 1221 (June 30, 2025), https://ofac.treasury.gov/faqs/added/2025-06-30.

⁵See OFAC, FAQ No. 1223 (June 30, 2025) https://ofac.treasury.gov/faqs/added/2025-06-30.

⁶15 C.F.R. § 746.9(a). In contrast to other sanctions regimes, the relevant regulations and licenses for sanctions against Syria did not include an exemption from U.S. export controls. See 15 C.F.R. § 746.9(a) (“{a} license is required for the export or reexport to Syria of all items subject to the EAR, except food and medicine . . ..”).