Client Alert 12/19/2025
The full client alert is available here.
On December 18, 2025, President Trump signed into law the National Defense Authorization Act for Fiscal Year 2026 (“NDAA 2026”). The NDAA 2026 specifies the budget, expenditures and policies of the U.S. Department of Defense for 2026. Section 6211 of the NDAA 2026 repeals the Caesar Syrian Civilian Protection Act of 2019 (“Caesar Act”). The Act was signed into law by President Trump in December 2019 and came into force on June 17, 2020. Following the repeal in the NDAA 2026, the Caesar Act, which sanctioned foreign persons who knowingly provided significant financial, material, or technological support to the Government of Syria, is no longer in force.
The repeal of the Caesar Act is the latest step taken by the U.S. Government to ease sanctions on Syria. The gradual removal of sanctions began with the issuance of General License 24 in January 2025, followed by General License 25 in May 2025, a 180-day suspension of the Caesar Act in May 2025, the issuance of Executive Order 14312 in June 2025 directing U.S. agencies to take measures to lift sanctions and export controls on Syria, and a second 180-day suspension of the Caesar Act in November 2025.
While the U.S. no longer imposes the comprehensive sanctions on Syria set forth by the Caesar Act, certain Syrian actors, including former President Bashar Al-Assad, Captagon traffickers and persons linked to ISIS and Al-Qa’ida, remain subject to sanctions. Moreover, Syria is still designated a State Sponsor of Terrorism. State Sponsors of Terrorism are subject to restrictions on U.S. foreign assistance; a ban on defense exports and sales; certain controls over exports of dual-use items; and miscellaneous financial and other restrictions. The Secretary of State was ordered to review Syria’s designation as a State Sponsor of Terrorism in Executive Order 14312, but no public action has been taken to date.
The repeal of the Caesar Act follows Syrian President Ahmed Al-Sharaa’s visit to Washington, DC on November 10, 2025, the first visit by a Syrian head of state to the White House since Syria gained independence in 1946. As reported in Curtis’ June 12, 2025 Client Alert, the U.K. and E.U. have also taken steps to ease sanctions targeting Syria with the goal of promoting foreign investment and assisting in the recovery and rebuilding of Syria.
Economic Sanctions
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John M. B. Balouziyeh
Partner
Kevin A. Meehan
Marwa Farag
Associate
Sara Lucía Dangón-Novoa
New York
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