On June 30, 2025, the White House issued Executive Order 14312, Providing for the Revocation of Syria Sanctions (the Syria EO), terminating U.S. comprehensive sanctions on Syria effective July 1, 2025. This action followed the issuance of General License 25 by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) on May 23, 2025, which waived many sanctions on the country. U.S. persons are now broadly authorized to provide services to and conduct financial transactions with Syrian individuals, entities, and the Government of Syria, subject to compliance with remaining sanctions and export control restrictions.

Extensive export controls remain in place for now, prohibiting the supply of nearly all goods, software, and technical data subject to U.S. export control jurisdiction to Syria other than food and medicine. The Syria EO directs the government to begin the process to roll back some of these controls, but these changes have not yet been implemented.

The Syria EO – Reduced Sanctions and Export Controls on Syria

Sanctions

The Syria EO revoked comprehensive OFAC sanctions on Syria. As a result, persons blocked solely under OFAC’s Syrian Sanctions Regulations (31 C.F.R. Part 542), including the Government of Syria, were removed from OFAC’s list of Specially Designated Nationals and Blocked Persons (SDN List), and all property and interests in property of such persons are unblocked. Additionally, all entities owned, either directly or indirectly, 50% or more by one or more such persons are also unblocked. The revocation also lifts restrictions on services and financial transactions involving Syria.

The Syria EO also provided OFAC the authority to target former president of Syria, Bashar al-Assad and his associates, human rights abusers, captagon drug traffickers, and other destabilizing regional actors. Accordingly, OFAC designated 139 persons on the SDN List who were previously designated under the Syrian Sanctions Regulations and other OFAC authorities. These designations form the new OFAC Promoting Accountability for Assad and Regional Stabilization Sanctions Program. There are still many sanctioned parties headquartered or operating in Syria, and the country remains a relatively high-risk jurisdiction, although comprehensive sanctions have been lifted.

OFAC issued updated frequently asked questions regarding the lifting of Syria sanctions confirming that all Syrian financial institutions, including the Central Bank of Syria, have been removed from the SDN List. The FAQs also explain that U.S. persons may provide financial services to Syria, process payments on behalf of third country financial institutions involving Syrian financial institutions, and conduct transactions with the new Government of Syria and Syrian financial institutions, including by establishing correspondent banking relationships with Syrian financial institutions, provided that none of the parties to such transactions are on the SDN List.

Export Controls & Other Restrictions

The Syria EO initiated the process to begin lifting comprehensive U.S. export controls on Syria. Under current rules, the U.S. Export Administration Regulations (EAR) prohibit the export, reexport, and transfer (in-country) of all items “subject to the EAR” to Syria other than food and medicine. These restrictions, which apply to dual-use items listed on the EAR’s Commerce Control List (CCL) and also to non-sensitive EAR99 items, are imposed pursuant to statutory requirements, including those under the Syria Accountability and Lebanese Sovereignty Restoration Act of 2003 (Syria Act) and the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (CBW Act).

The EO took the first step to lift those restrictions. First, the President determined that waiver of many export controls on CCL-listed and EAR99 items imposed by the Syria Act is in the national security interest of the United States. Once such a determination has been made, the Syria Act allows for the lifting of export controls following submission of an explanatory report to Congress. The Syria EO directs the Secretary of State to submit such a report to Congress.

Second, the U.S. government has maintained export controls on Syria under the CBW Act in response to actions taken by Assad. These controls restrict exports of national security-sensitive goods and technology, foreign assistance, U.S. government credit and other financial assistance, and private loans or credit from U.S. private financial institutions. The CBW Act authorizes the President to waive the above restrictions if the President determines and certifies to Congress that there has been a fundamental change in the leadership and policies of the government of the sanctioned country, and if the President notifies Congress at least 20 days before the waiver takes effect. The Syria EO determined such a fundamental change in the leadership and policies of the Government of Syria, waived the sanctions imposed under the CBW Act, and directed the Secretary of State to transmit the waiver to Congress, noting that the waiver will be effective 20 days after it has been so transmitted.

Third, the Syria EO directed the Secretary of State to review Syria’s designation as a State Sponsor of Terrorism (SST), which prohibits U.S. foreign assistance, defense exports and sales, exports of certain dual-use items, and certain financial and other transactions with respect to Syria. In order to remove Syria’s SST designation, the President must first submit a report to Congress detailing the reasons for removal.

Additionally, following the Syria EO, the State Department waived sanctions on certain Syrian individuals and entities that were sanctioned under the Caesar Syria Civilian Protection Act of 2019, and for certain Syrian government defense entities sanctioned under other U.S. authorities.

Next Steps & Considerations

• We expect that the State Department will provide notices to Congress as directed by the EO to liberalize export controls on Syria. The Department of Commerce Bureau of Industry and Security will then likely amend the EAR to lift certain export controls on Syria. It is important to note that more sensitive dual-use and military items will very likely remain subject to a licensing requirement for export, reexport, and transfer (in-country) to Syria pursuant to commitments under multilateral export controls arrangements and U.S. national and foreign security policies.
• While the U.S. has terminated comprehensive sanctions on Syria, the situation remains fluid, and the U.S. government could reinstate some or all restrictions if conditions change.
• As such, companies should proceed with caution when conducting transactions with the Government of Syria and Syrian individuals and entities, with robust compliance guardrails and the ability to exit or restrict activity in the market, as required.
• As noted, Syria remains a high-risk jurisdiction, and companies thinking about re-entering the market should adopt adequate restricted party screening processes to identify sanctioned parties.
• Companies should keep in mind that their banking partners and other financial institutions may not rapidly reverse compliance requirements related to Syria, including covenants in funding agreements and compliance certifications.
• Companies should ensure that they understand what non-U.S. restrictions may apply to dealings in Syria, including trade controls and sanctions imposed by the European Union and other jurisdictions.

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