U.S. Lifts Most Sanctions on Syria in Major Policy Development

On June 30, 2025, President Trump issued Executive Order 14312 effectively lifting (or beginning the process of lifting) most of the sanctions on Syria. Executive Order 14312 cites the leadership changes and the policies of the new Syrian government under President Ahmed al-Sharaa as the reasons for the removal of sanctions. On the same day, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of State took steps to implement the termination of the program by, among other actions, delisting appropriate individuals and entities from the List of Specially Designated Nationals and Blocked Persons (SDN List). These actions followed the initial sanctions relief provided on May 23, 2025 by OFAC, the Financial Crimes Enforcement Network (FinCEN), and the State Department.

Executive Order 14312 provides for the maintenance of sanctions on individuals associated with the former Assad government, or involved in other harmful activities, including the production or sale of Captagon and in human rights abuses, under the new Promoting Accountability for Assad and Regional Stabilization Sanctions (PAARSS) program. Accordingly, OFAC re-listed under PAARSS a number of persons who were de-listed under the prior Syria program.

While some uncertainty remains, and not all of the actions are immediately effective, this announcement breathes new life into the economic conditions in Syria, and opportunities for transactions involving Syria and formerly sanctioned persons in Syria.

I. Immediate Revocation of Syrian Embargo and Related Sanctions

Effective as of July 1, 2025, President Trump revoked the national emergency declared under Executive Order 13338 along with six executive orders (13338, 13399, 13460, 13572, and 13582) which served as the vehicles for many of the Syria sanctions.

The revocation of these six executive orders makes a number of key changes to prior prohibitions, including that:

• U.S. persons can engage in new investment in Syria;
• U.S. persons can export, reexport, sell, or supply, directly or indirectly, services to Syria;
• Persons can import Syrian origin petroleum and petroleum products into the United States;
• U.S. persons can engage in transactions to purchase, sell, transport, swap, broker, approve, finance, facilitate, or guarantee, in or related to petroleum or petroleum products of Syrian origin; and
• OFAC removed 518 individuals and entities from the SDN List who were previously sanctioned under the Syria sanctions program. Provided such persons are not subject to restrictions under any other U.S. sanctions program (e.g., counterterrorism, Iran, Russia, counternarcotics), U.S. persons are now authorized to: (i) deal with these individuals and entities (and any entities they own, in the aggregate 50% or more); and (ii) can unblock all property that these individuals and entities have an interest in.

The Government of Syria was among those de-listed, but the Government of Syria remains a designated State Sponsor of Terror (SST) and is controlled by many individuals associated with Hay’at Tahrir al-Sham (HTS). On July 7, 2025, the Department of State revoked the Foreign Terrorist Organization (FTO) designation of HTS effective July 8, 2025, noting the announced dissolution of HTS and the Syrian government’s commitment to combat terrorism. However, HTS remains a Specially Designated Global Terrorist (SDGT) with associated restrictions outlined in OFAC’s Global Terrorism Sanctions Regulations. Executive Order 14312 directs the U.S. Departments of State, Treasury, and Justice to review the SDGT designations of both HTS and Syrian President Abu Muhammad al Jawlani, although the timeline for any additional relief remains uncertain.

Previously-issued OFAC General Licenses remain in effect that apply to many dealings with the Government of Syria, but such dealings do still involve U.S. sanctions risks and should be subject to appropriate diligence.

II. Additional Steps to Reduce Sanctions and Export Controls

Process to Reduce Export Controls on Syria

Currently, all items subject to the U.S. Export Administration Regulations (EAR), other than food or medicine classified EAR99, require a license or license exception for export to Syria. Additionally, the “de minimis” threshold for U.S. origin components of non-U.S. origin items for reexports and transfers to Syria is lower (10%, compared to 25% in most other instances), due to Syria’s SST designation and its inclusion in “Country Group E”.

The President, in Executive Order 14312, took steps to set in motion the substantial removal of these export controls by:

1. Syria Accountability Act: Waiving prohibitions in the Syria Accountability Act on the export to Syria of items on the Commerce Control List (section 5(a)(1)) and of U.S. products other than food or medicine (section 5(a)(2)(A)), which will be effective upon submission by the Secretary of State of a report to Congress explaining the waiver;
2. Chemical and Biological Weapons Control and Warfare Elimination Act: Waiving the sanctions (under section 307(d)(1)(B) of the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991) relating to the former Assad regime’s use of chemical weapons, including restrictions on: (1) foreign assistance to Syria; (2) U.S. Government credit, credit guarantees, and other financial assistance; (3) the export of national security-sensitive goods and technology, as well as all other goods and technology; and (4) U.S. banks from providing loans or credit to the Syrian government (this waiver will be effective 20 days after the Department of State transmits the waiver determination to the appropriate Congressional committees); and
3. State Sponsor of Terrorism Designation: Directing the Department of State to review Syria’s designation as a State Sponsor of Terrorism (as of the date of publication, the State Department has not announced any determinations in this respect—depending on the approach taken, a potential rescission may involve a 45-day waiting period from the day the Secretary of State submits the appropriate report to Congress to the day the rescission becomes effective).

Collectively, if each of these waivers and designations are reviewed, and ultimately revoked, Syria will be removed from “Country Group E” of the EAR and from Part 746 of the EAR (Embargoes and Other Special Controls). These changes will mean that: (i) all items subject to the U.S. Export Administration Regulations that are classified for anti-terrorism purposes only or are EAR99 will be authorized for export to Syria; (ii) persons can rely on more EAR license exceptions to export these items; and (iii) the de minimis threshold for non-U.S. origin items will increase to 25% (instead of 10%).

Caesar Act Sanctions

President Trump has also ordered the Secretary of State and the Secretary of the Treasury to examine whether the conditions have been met for the suspension of sanctions under the Caesar Syria Civilian Protection Act (Caesar Act). Section 7431 of the Act sets out these conditions, which include that (i) the Syrian, Russian, and Iranian governments are no longer engaged in a variety of acts targeting civilians in Syria, and that previous areas of conflict are no longer cut off from international aid; (ii) the Syrian Government releases political prisoners and allows for investigations; (iii) the Syrian Government is permitting the return of displaced Syrians; and (iv) the Syrian Government is holding to account perpetrators of war crimes.

If these conditions (among others) are met, the Secretary of State may suspend sanctions under the Caesar Act, but if at a later date the conditions are no longer met, the Secretary of State is directed to reimpose these sanctions.

In the meantime, the Secretary of State’s previous May 23 waiver of sanctions under the Caesar Act remains in effect. Additionally, on June 30 the Secretary of State waived the application of sanctions for a number of individuals and entities previously designated under the Caesar Act.

The Secretary of State also terminated sanctions under Executive Order 13894 on the First and Fourth Divisions of the Syrian Arab Army, and the National Defense Forces, and under the Iran Sanctions Act, on Sytrol. OFAC delisted all of the aforementioned individuals and entities from the SDN List.

Proposed United Nations Support for Syria

The UN does not have a “Syria” sanctions program, but HTS itself and a number of persons affiliated with HTS remain designated under UN sanctions for terror-related actions. Executive Order 14312 directs the Secretary of State to “explore avenues at the United Nations to provide sanctions relief in support of” a stable Syria and Syrian efforts to counter terrorism and comply with its responsibilities and obligations concerning weapons of mass destruction, including chemical and biological weapons. Such relief likely would require action by the relevant sanctions committee of the U.N. Security Council.

III. Expansion of Sanctions on Assad Government Officials

Notwithstanding the changes above, Executive Order 14312 requires the imposition of additional sanctions on individuals associated with the former Assad government as well as individuals involved in the production or sale of captagon, individuals involved in human rights abuses, or anyone found to have materially assisted, sponsored, or provided support for individuals whose assets have been blocked due to the above.

Executive Order 14312, the basis for the new Promoting Accountability for Assad and Regional Stabilization Sanctions (PAARSS) program, amended Executive Order 13894, which itself was the basis for certain prior Syria-related sanctions, as well as short lived sanctions on Turkey. Executive Order 14312 expanded the scope of the national emergency declared in Executive Order 13894 and tailored the language as applicable towards the former regime of Bashar al-Assad, including, among other categories: members or those acting on behalf of the former regime; those who have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of, the former regime; and adult family members of any person designated by the order.

In light of this requirement, OFAC added 139 individuals and entities to the SDN List under the new PAARSS program and may continue using this authority to designate additional individuals or entities in the future.

IV. What’s Next

• With these actions, most U.S. sanctions on Syria have been lifted. However, a range of restrictions continue to apply, including U.S. export controls and restrictions under Syria’s SST designation. While these may gradually be removed in the coming weeks and months, these actions and their timing remain uncertain.
• In addition, there are still a large number of individuals and entities in Syria that are designated under other sanctions authorities, including the newly redesigned PAARSS program as well as long-standing counter-terrorism authorities. Transactions involving Syria remain subject to a range of sanctions and export control risks and companies should continue to exercise appropriate diligence around transactions involving Syria to account for these risks.
• Any pending or future OFAC or Department of Justice investigations or enforcement actions related to apparent violations of the Syrian Sanctions Regulations that occurred prior to July 1, 2025, may still be carried out, which was illustrated in a settlement OFAC announced on July 15, 2025.
• Companies should be prepared for financial institutions and insurers, among others, to require heightened diligence or potentially refuse or delay transactions due to these ongoing risks. As was the case when the United States lifted sanctions on Sudan and after initially signing the Joint Comprehensive Plan of Action (JCPOA) with Iran, it appropriately will take time for the private sector to regain comfort in dealing with Syria.