The U.S., U.K., and E.U. Ease Sanctions Targeting Syria

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On May 23, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Syria General License 25 (“GL 25”), providing broad sanctions relief for Syria. Concurrently, the U.S. Department of State issued a waiver under the Caesar Syria Civilian Protection Act (“Caesar Act”), lifting secondary sanctions against foreign persons who engage in transactions prohibited to U.S. persons by the Syrian Sanctions Regulations and other sanctions programs. The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) also provided exceptive relief under Section 311 of the USA PATRIOT ACT, conditionally permitting certain financial institutions to open and maintain correspondent accounts for the Commercial Bank of Syria. The U.K. and the E.U. have also eased sanctions against Syria to assist in the economic recovery of Syria.

Syria General License 25
The purpose of GL 25 is to help Syria rebuild its economy, financial sector, and infrastructure by permitting new investment into Syria. GL 25 authorizes transactions prohibited by the Syrian Sanctions Regulations. It also authorizes transactions involving the provision of services to people and companies in Syria, new investment in Syria, dealing in petroleum and petroleum products from Syria, transactions with the new Government of Syria, and transactions involving blocked persons listed in GL 25’s Annex, including the Central Bank of Syria. GL 25 serves as a key step in attracting foreign investment and assisting in the rebuilding of Syria.

GL 25 does not authorize transactions involving individuals or entities on OFAC’s SDN List, unless they are listed in the Annex to GL 25, including former President Bashar al Assad. Furthermore, GL 25 does not permit the unblocking of property or interests in property of any person, nor does it permit transactions for or on behalf of the governments of the Russian Federation, Iran, or the Democratic People’s Republic of Korea. Additionally, GL 25, while now permitting the export of services to Syria, does not affect the prohibition under the Syria Accountability and Lebanese Sovereignty Restoration Act of 2003 (SAA) on the export of items listed on the Commerce Control List and other U.S. products other than food and medicine. A license is still required from the Bureau of Industry and Security to export such items and products to Syria.

GL 24, which was issued on January 6, 2025 and provides limited sanctions relief to ensure that the Syrian people have access to essential services such as electricity, water, energy, and sanitation following the end of Bashar al-Assad’s rule, remains effective until July 7, 2025. Click here to read Curtis’ earlier client alert relating to GL 24.

Caesar Syria Civilian Protection Act Waiver
On May 23, 2025, Secretary of State Marco Rubio waived the application of sanctions under the Caesar Act with respect to foreign persons for 180 days. Non-U.S. persons do not risk exposure under U.S. sanctions for engaging in activities or facilitating transactions or payments for activities that would be authorized for U.S. persons pursuant to GL 25.

U.K. and E.U. Also Ease Sanctions on Syria
The United Kingdom moved to lift sanctions on Syria by amending the Syria (Sanctions) (E.U. Exit) Regulations 2019 (the “Regulations”) on April 25, 2025. The amendment to the Regulations removes sanctions on energy, aircraft transport, financial transactions, trade, and exemptions on financial/credit institutions. In addition, sanctions were lifted on over 12 Syrian entities, including the Syrian Ministry of Defense, the Ministry of Interior, and several media companies. The amended Regulations apply to U.K. persons’ conduct that is wholly or partly outside the U.K. The amended Regulations maintain sanctions against the al Assad regime, as well as trade restrictions on the import of military goods and technology, the export of goods and technology relating to chemical and biological weapons and relating to internal repression, and the export of goods and technology related to interception and monitoring.

On May 28, 2025, the E.U. Council agreed to lift all economic sanctions on Syria, except sanctions that are based on security reasons. In addition, the E.U. Council removed 24 entities from its sanctions list, including the Central Bank of Syria and companies operating in critical sectors of the Syrian economy. The Council has maintained the listing of individuals and entities linked to the al Assad regime until June 1, 2026.

Takeaways
The easing of sanctions on Syria by the U.K., E.U., and the U.S. serves to promote investment in Syria with the goal of assisting in the recovery and rebuilding of Syria and the new Syrian Government. While no jurisdiction has completely eliminated the Syrian sanctions program, all have provided broad sanctions relief. For example, the Caesar Act waiver for foreign persons together with GL 25 eases most U.S. sanctions against Syria and promotes engagement with Syria by U.S. and foreign persons. U.S. and non-U.S. individuals and entities may engage in transactions for critical services in Syria, including in the education, telecommunications, healthcare, agriculture, transportation, construction, water, waste management, and financial sectors.

Notably, the prohibition on the export of U.S. goods to Syria remains in place, and Syria remains designated as a State Sponsor of Terrorism.