On May 23, 2025, the Trump administration issued a general license (GL) significantly relaxing the patchwork of restrictions on Syria, long a jurisdiction subject to comprehensive sanctions. This regulatory action followed a statement from President Trump during a recent trip to the Middle East that he would lift U.S. sanctions on Syria.
While this development provides meaningful sanctions relief, companies still need to exercise care, as export controls and other key restrictions on Syria remain in place and the administration has the flexibility to revoke the GL at any time.
Through GL 25 “Authorizing Transactions Prohibited by the Syrian Sanctions Regulations or Involving Certain Blocked Persons,” the Treasury Department’s Office of Foreign Assets Control (OFAC) has indefinitely authorized a variety of U.S. person activities vis-à-vis Syria that have previously been prohibited, including investment in and the provision of services to Syria and transactions involving certain prominent parties on OFAC’s Specially Designated Nationals and Blocked Persons (SDN) List, including the Government of Syria. OFAC has since issued additional guidance clarifying the scope and intention of the GL.
OFAC stated that the issuance of GL 25 will “facilitate activity across all sectors of the Syrian economy, without providing relief to terrorist organizations, perpetrators of human rights abuses and war crimes, drug traffickers, or the former Assad regime.” The broad authorization is intended to help kickstart rebuilding in a country devastated by over a decade of fierce internecine conflict.
As discussed below, key U.S. allies, including the EU and U.K., have also begun relaxing their sanctions on Syria.
General License 25
OFAC’s Syria sanctions program includes a wide range of restrictions on U.S.-person activities (e.g., prohibitions on new investment, the provision of services and involvement in the energy sector) and a number of list-based prohibitions imposing blocking sanctions on persons implicated in terrorism, narcotics trafficking, human rights abuses, political meddling, sanctions evasion and proliferation related to Syria.
GL 25 indefinitely and broadly authorizes many of these previously restricted and/or prohibited activities, specifically:
- All transactions prohibited by the Syrian Sanctions Regulations (31 CFR part 542), other than transactions involving blocked persons not specified below.1
-
All transactions prohibited by the
Syrian Sanctions Regulations, or the Weapons of Mass Destruction Proliferators
Sanctions Regulations (31 C.F.R. part 544), the Iranian Financial Sanctions
Regulations (31 C.F.R. part 561), the Global Terrorism Sanctions Regulations
(31 C.F.R. part 594), the Foreign Terrorist Organizations Sanctions
Regulations (31 C.F.R. part 597), or Executive Order 13574 involving the
following blocked persons:
- The Government of Syria.
- Any blocked person listed in the annex to GL 25.
- Any entity in which one or more of the blocked persons in the annex to GL 25 own, directly or indirectly, individually or in the aggregate, a 50% or greater interest.
GL 25 is much more sweeping than GL 24, issued on January 6, 2025, which provided limited sanctions relief. Among other things, GL 25 permits transactions involving prominent SDNs identified in the annex to the GL, including the Syrian government and several major banks and infrastructure-related enterprises in Syria.
The new authorization also removes restrictions on key U.S.-person activities such as investing in and providing services to Syria, and trading in Syrian energy products, so long as those activities do not involve an SDN not on the annex to GL 25.
In conjunction with the issuance of GL 25, Treasury’s Financial Crimes Enforcement Network (FinCEN) provided relief in connection with its rule imposing special measures against the Commercial Bank of Syria under Section 311 of the USA PATRIOT Act. U.S. financial institutions may now open and maintain correspondent accounts for the Commercial Bank of Syria (CBoS) under certain conditions.
Additionally, the State Department has issued a 180-day waiver of so-called secondary sanctions under the Caesar Act, which authorizes the U.S. government to impose financial consequences on non-U.S. persons engaged in specified sanctionable activities, such as human rights abuses. Secondary sanctions principally target non-U.S. persons for engaging in certain enumerated activities even if these activities have no U.S. nexus that would create U.S. sanctions jurisdiction.
Remaining Restrictions
While the GL dramatically opens up the range of permissible activity U.S. persons may engage in with respect to Syria, it expressly retains key restrictions, including on:
- Transactions involving SDNs and blocked persons not listed in the Annex of GL 25.
- Property blocked pursuant to OFAC’s sanctions authority as of the date of the GL.
- Transactions for or on behalf of Russia, Iran or North Korea.
GL 25 also does not relieve parties of their compliance obligations under other U.S. regulations related to Syria. In particular, U.S. export controls under the International Traffic in Arms Regulations (ITAR) and the Export Administration Act (EAR) continue to restrict virtually all exports, reexports or transfers to Syria other than “food” and “medicine” (as defined in the EAR) classified for export controls purposes as EAR99.
Additionally, the rebel military coalition that ultimately toppled the Assad regime, Hayat Tahrir al-Sham (HTS), which was led by current Syrian President Ahmad al-Sharaa, is still listed by the State Department as a Foreign Terrorist Organization. Absent further guidance suggesting otherwise, the provision of material support to HTS could create criminal exposure under 18 U.S.C. 2339B and should be considered at the due diligence stage of any transaction.
Relaxation of EU and U.K. Sanctions
Responding to the same geopolitical realities, other countries are also signaling their willingness to relax sanctions on Syria, including the EU and U.K. Notably on May 20, 2025, the Council of the European Union announced that the EU would lift its restrictive measures against Syria. From May 28, 2025, the EU gave effect to that pledge by lifting the majority of its sanctions on Syria. This step followed the suspension of some specific restrictive measures targeting Syria, notably in the energy and transport sectors, with effect from February 25, 2025, and the removal of five entities from the EU’s asset freeze list.
The EU's sectoral sanctions on Syria are now restricted to certain measures based on security grounds and the EU's list of asset freeze targets related to Syria has been narrowed yet further. This means that the remaining sanctions focus primarily on military, internal repression, internet or telephone monitoring or interception items, and cultural property goods. The remaining asset freeze targets are predominantly persons connected to the Assad regime, chemical weapons, human rights abuses and the illicit drugs trade.
For its part, the U.K. has, since March 2025, delisted a significant number of Syrian individuals and entities and narrowed the scope of its sectoral sanctions. However, hundreds of individuals and dozens of entities remain directly targeted with U.K. asset freezing sanctions, and other trade and financial restrictions remain in effect.
The remaining U.K. trade sanctions focus on items connected to chemical and biological weapons, military items, communications interception or monitoring items, internal repression items and luxury goods. There are also certain specific restrictions associated with the supply and delivery of gold, precious metals or diamonds to or from the Governing Authority of Syria. Associated services prohibitions attach to these trade-related prohibitions. The U.K. also continues to maintain restrictions associated with public bonds or public guaranteed bonds issued by the Assad regime.
See the Executive Briefing publication
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1 Including persons on the SDN list and any entity in which one or more of such SDNs own, directly or indirectly, individually or in the aggregate, a 50% or greater interest.
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