Trump Administration Issues Sweeping Sanctions Relief for Syria

Key Points

• On May 23, 2025, OFAC issued Syria GL 25, which authorizes a wide range of transactions otherwise prohibited by the SySR and other authorities affecting trade with Syria.
• Subject to certain exclusions, GL 25 includes (1) a broad lifting of the SySR prohibitions on U.S. person involvement in the provision of services to Syria, new investment in Syria, and transactions related to Syrian-origin petroleum or petroleum products; and (2) a more targeted lifting of sanctions on certain Syria-related “blocked persons” (including entities owned or controlled by the “Government of Syria”).
• Unlike GL 24, which OFAC issued in January 2025 shortly after the fall of the Assad regime, GL 25 does not have an expiration date. Treasury Secretary Scott Bessent indicated that GL 25 is designed to “encourage new investment into Syria,” “support the new Government of Syria” and “put the country on a path to a bright, prosperous, and stable future.” This OFAC action follows recent efforts by the EU to initially suspend and subsequently lift sanctions, and by the UK to lift certain of its sanctions on Syria.
• GL 25 does not authorize any transactions involving blocked persons other than those listed in the GL’s Annex, the unblocking of property or interests in property blocked before May 23, 2025, or certain transactions involving Russia, Iran, or North Korea.
• Concurrently, the State Department issued a 180-day waiver of secondary sanctions under the Caesar Act. Non-U.S. persons may now transact with covered sectors of the Syrian economy, including Syria’s petroleum sector, without risk of secondary sanctions so long as their activities are consistent with the waiver’s conditions.
• U.S. export controls on Syria (control of items subject to the EAR and ITAR) as well as blocking sanctions on individuals and entities linked to the Assad regime that are not listed in the GL’s Annex remain in place.

Overview

On May 23, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License (GL) 25 to provide immediate sanctions relief for Syria in line with President Trump’s May 13, 2025 announcement during a visit to the Kingdom of Saudi Arabia ordering the cessation of sanctions against Syria to allow the country to move forward with “a chance at greatness.” The Department of the Treasury stated in its press release that the GL’s purpose is to “help rebuild Syria’s economy, financial sector, and infrastructure, in line with U.S. foreign policy interests. To do this, it is critical to bring new investment into Syria and support the new Government of Syria.”

Although GL 25 does not lift all sanctions on Syria, it provides broad relief from the Syrian Sanctions Regulations’s (SySR) comprehensive prohibition on the provision of services to Syria, new investment in Syria, and transactions involving Syrian-origin petroleum or petroleum products (including imports of these products to the United States).

Summary of GL 25

Paragraph (a) – the General Prohibitions

Subject to certain limitations, paragraph (a) of GL 25 authorizes, with limited exceptions, “all transactions prohibited by the [SySR],” which is codified at 31 C.F.R. Part 542. This includes the broad “services” prohibition (542.207) on the “exportation, reexportation, sale, or supply, directly or indirectly, from the United States, or by a United States person, wherever located, of any services to Syria,” including individuals or entities located in or ordinarily resident in Syria. Along with this services prohibition, the prohibitions on “new investment” in Syria (542.206) and dealings in Syrian-origin petroleum or petroleum products (542.208 and 542.209) form the core of the U.S. sanctions prohibitions on Syria.

Paragraph (b) – the Blocked Person Prohibitions

Paragraph (b) of the GL authorizes transactions involving specified blocked persons, i.e., (1) the “Government of Syria,” as defined by 31 C.F.R. § 542.308, as in existence on or after May 13, 2025 (which includes “Syrian President Ahmed al-Sharaa and his government”); and (2) the persons designated on OFAC’s List of Specially Designated Nationals and Blocked Persons (SDNs) that are listed in the Annex to the GL and persons owned 50 percent or more, directly or indirectly, individually or in the aggregate, by such persons.

GL 25 expressly licenses against multiple sanctions authorities beyond the SySR because the SDNs that appear in the Annex, including President al-Sharaa (formerly known under the nom de guerre Abu Muhammad Al-Jawlani, as described in the GL’s “Note to paragraph (b)(1)”), are collectively blocked pursuant a variety of sanctions authorities. For example, Commercial Bank of Syria is blocked pursuant to the Weapons of Mass Destruction Proliferators Sanctions Regulations (WMDPSR), the Central Bank of Syria is blocked solely pursuant to the SySR, and Syrian Arab Airlines is blocked pursuant to both the SySR and the Global Terrorism Sanctions Regulations (GTSR).

In addition, President al-Sharaa, is an individual blocked pursuant to the GTSR (as a Specially Designated Global Terrorist (SDGT)), as well as the Foreign Terrorist Organizations Sanctions Regulations (FTOSR) (for his association with a Foreign Terrorist Organization (FTO)) by operation of law due to being an “agent” of the SDGT and FTO Hay’at Tahrir al-Sham, of which he is the leader.

GL 25 licenses against all these authorities, and appears aimed at ensuring that, for each blocked person listed in the Annex to the GL, the authorities covered by the GL are sufficient to authorize dealings with that person.

Paragraph (c) – the Carveouts

Paragraphs (a) and (b) of GL 25 are subject to three carveouts or exclusions at paragraph (c): (1) a carveout for any transactions involving blocked persons other than those listed in the Annex to the GL, unless separately authorized; (2) a carveout for the unblocking of any property or interests in property blocked pursuant to any part of 31 C.F.R. chapter V as of May 22, 2025; and (3) a carveout for “[a]ny transactions for or on behalf of the Government of the Russian Federation, the Government of Iran, the Government of the Democratic People’s Republic of Korea (DPRK), or related to the transfer or provision of goods, technology, software, funds, financing, or services to or from Iran, Russia, or the DPRK.”

Relationship between Syria GL 25 and GL 24

After the fall of the Assad regime in December 2024, OFAC issued GL 24 on January 6, 2025. GL 24, which has an expiration date of July 7, 2025, authorizes transactions with governing institutions in Syria after December 8, 2024; transactions in support of the sale, supply, storage, or donation of energy (including petroleum, petroleum products, natural gas, and electricity) to or within Syria; and transactions ordinarily incident and necessary to processing the transfer of noncommercial, personal remittances to Syria, including through the Central Bank of Syria.

Notably, GL 24 does not lift the SySR prohibitions on the importation of Syrian-origin petroleum or petroleum products into the United States, most new investment in Syria by U.S. persons, and transactions involving the supply or export of most services to Syria. GL 25, however, effectively lifts these prohibitions.

Additionally, GL 24 only authorizes transactions with “governing institutions in Syria following December 8, 2024,” while GL 25 now authorizes transactions with the “Government of Syria” as in existence on or after May 13, 2025. The “Government of Syria” is defined broadly at 31 C.F.R. 542.308 and includes companies that are majority owned or controlled by the Syrian government.

While GL 24 is set to expire six months after its issuance, GL 25 does not have an expiration date and, thus, can remain effective indefinitely. However, OFAC can revoke its GLs at will “if appropriate to support U.S. foreign policy and national security priorities,” as recently seen in the Venezuela context during the Biden administration and the current Trump administration. OFAC’s approach to Syrian sanctions relief thus far somewhat resembles the approach taken by the Obama administration to provide sanctions relief to Sudan, which began in January 2017 with, among other executive actions, the issuance of a general license authorizing U.S. person activities prohibited by the Sudanese Sanctions Regulations, and ultimately resulted in the revocation of the Sudanese Sanctions Regulations, effective October 12, 2017, after Sudan demonstrated progress in certain key policy areas identified by the U.S. government.

OFAC plans to issue further guidance related to GL 25 in the coming days and weeks.

Caesar Act Secondary Sanctions Waived for 180 Days

Concurrent with the issuance of GL 25, the U.S. State Department issued a 180-day waiver to the Caesar Syria Civilian Protection Act of 2019 (Caesar Act, 22 U.S.C. §8791 note). The Caesar Act requires the President to impose sanctions on foreign (i.e., non-U.S.) persons who “knowingly” engaging in certain Syria-related activities, including engaging in “significant” transactions with the Government of Syria or any other foreign person subject to sanctions with respect to Syria; providing significant construction or engineering services in Syria; providing significant support to maintaining or expanding Syria’s domestic production of natural gas, petroleum or petroleum products; or providing aircraft, aircraft parts or significant related goods or services for, on behalf of, or to the Government of Syria for military purposes in Syria. However, the Caesar Act allows for the President to waive the application of any provisions of the Act for a renewable period of 180 days “if the President certifies to the appropriate congressional committees that such a waiver is in the national security interests of the United States.”

However, while this waiver has the important practical effect of providing comfort to potential non-U.S. person market participants in Syria, the technical legal importance of this waiver appears to be limited, given that OFAC FAQ guidance indicates that non-U.S. persons do not face secondary sanctions risks for engaging in activity that is authorized for U.S. persons under a GL. That said, taken together, the State Department’s waiver and GL 25 enable non-U.S. companies to provide the above services or enter into transactions contemplated by the Caesar Act with reassurance that they will not be subject to secondary sanctions and designated as SDNs for their activities, at least during the effective period of the 180-day waiver, so long as they meet the conditions the waiver includes.

FinCEN Issues Exception to Prohibition Imposed by Section 311 of the Patriot Act Against the Commercial Bank of Syria

Also on May 23, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a waiver that allows covered financial institutions to open and maintain correspondent accounts for the Commercial Bank of Syria subject to certain conditions. This additional relief further indicates the sweeping relief the Trump Administration is seeking to implement, including permitting transactions with Syria through the U.S. financial system.

Continuing Trade-Related Restrictions

While the issuance of GL 25 and the Caesar Act waiver provide sweeping sanctions relief to Syria and appear to be part of an effort to “effectively lift sanctions on Syria,” a number of Syria-related restrictions remain that are relevant to U.S. and non-U.S. persons. We note the Department of the Treasury’s press release statement that this action “is just one part of a broader U.S. government effort to remove the full architecture of sanctions imposed on Syria due to the abuses of the Bashar al-Assad regime,” so there will likely be additional measures to provide further sanctions relief.

1. List-based Sanctions

• • OFAC retains other sanctions authorities to designate Syrian persons on the SDN List. Companies should therefore continue to screen parties (whether associated with Syria-related transactions or otherwise) against the SDN List notwithstanding the recent changes. Notably, GL 25 does not authorize any transactions pursuant to the Syria-Related Sanctions Regulations (31 C.F.R. Part 569). These sanctions regulations are legally distinct from the SySR and primarily target members of the deposed government of Bashar Al-Assad and their companies. Persons designated under this sanctions regime appear under the [SYRIA-EO13894] “Program Tag” on the SDN List. In addition, as noted above, GL 25 does not authorize any transactions under the GTSR or FTOSR beyond those with persons listed in the Annex.

2. Certain Syria-related Transactions Involving Russia, Iran or the DPRK Remain Prohibited

• • As noted above, GL 25 explicitly excludes from the scope of its authorization any “transactions for or on behalf of” the governments of Russia, Iran or the DPRK, as well as any transactions relating to the transfer or provision of goods, technology, software, funds, financing, or services to or from Russia, Iran or the DPRK. Accordingly, such transactions remain prohibited.

3. U.S. Export Controls on Syria Remain in Place

• • OFAC’s GL 25 specifies that it does not provide any relief for obligations under the Department of Commerce’s Export Administration Regulations (EAR) or the State Department’s International Traffic in Arms Regulations (ITAR).
  • Both U.S. and non-U.S. persons require authorization from the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) to export or reexport all items subject to the EAR (i.e., all U.S. origin goods whereover located and certain foreign origin goods) other than food or medicine designated as EAR99, as described in 15 C.F.R. 746.9. While EAR99 medicines may not require a license, medicines (including vaccines and immunotoxins) on the Commerce Control List (CCL) still require a license from BIS to export or reexport to Syria. Furthermore, exports of medical devices still require a license from BIS. Currently, the only license exceptions available for Syria are listed in 15 C.F.R. 746.9(b). BIS cannot provide significant further relief on Syria until the President takes certain actions as required by the Syria Accountability and Lebanese Sovereignty Restoration Act of 2003, 22 U.S.C. 2151.
  • Additionally, Syria remains a jurisdiction where all exports of defense articles and defense services require a license from the Department of State’s Directorate of Defense Trade Controls (DDTC) and are subject to a policy of denial under the ITAR. (22 C.F.R. 126.1(d)(1)).
  • Even if exporters can provide goods or services to Syria under GL 25 without running afoul of OFAC’s regulations, licenses are still needed to comply with BIS’s and DDTC’s regulations, where applicable, absent further relief provided by those agencies.

4. Syria Remains on the State Sponsor of Terrorism List

• • The U.S. State Department designated Syria as a State Sponsor of Terrorism (SST) in 1979, and that designation currently remains in place. This designation imposes a ban on defense exports and sales, as well as certain controls over exports of dual-use items. It also includes the imposition of miscellaneous restrictions, such as limitations on economic assistance, an exception to foreign sovereign immunity for plaintiffs seeking to enforce terrorism-related judgments for compensatory damages against the blocked assets of the SST, and a ban on U.S. Department of Defense contracts above $100,000 with companies controlled by the Government of Syria.

5. Certain EU/UK Sanctions Related to the Assad Regime Remain in Place and Relief is Conditional

• • On May 20, 2025, following an initial suspension, the European Union (EU) Council announced that it will also be lifting economic sanctions on Syria, while maintaining sanctions related to the Assad regime and human rights violations. Notably, the EU sanctions relief is “reversible and conditional on progress.” The United Kingdom has made similar announcements.

Further Implications

The issuance of GL 25 and the Caesar Act waiver provide sweeping sanctions relief to Syria. As a result, U.S. and non-U.S. companies alike may, as a general matter, engage in most transactions involving Syria and persons ordinarily resident in Syria without the prior sanctions risks, subject to compliance with the conditions of the GL and the waiver.

Because of these conditions, performing sanctions screening, due diligence and risk assessments remains important, as prohibitions on transacting with certain Syrian actors remain in place. In particular, companies may wish to engage in export control jurisdiction and classification analyses as a matter of priority in assessing whether to engage in any Syria-related business that would involve the export or reexport of hardware, software or technology to Syria, in order to ensure that such items are not subject to the EAR.

In addition, companies planning to enter into long-term contracts for services or to make investments or loans with an extended horizon should recognize that GL 25’s relief could be lifted by OFAC at any time, as the U.S. government has made clear that it “will continue monitoring Syria’s progress and developments on the ground.” On prior occasions, OFAC has authorized only a brief period during which to “wind down” transactions following the revocation of a general license.

Notably, given that Syria has long been a target of extensive sanctions by the U.S. government, we expect that many financial institutions could remain cautious in processing certain Syria-related transactions as a matter of business or reputational risk or other considerations. Relatedly, it is market-standard to find broad contractual restrictions on activities, transactions, and other dealings involving Syria and/or persons located, resident or incorporated in Syria, including in credit, equity and other types of agreements, as well as investor side letters. Depending on how these provisions are drafted, those contractual restrictions may remain in effect even with the lifting of U.S. sanctions.

Finally, certain U.S. states—including Michigan—impose divestment requirements and investment prohibitions on public funds with respect to companies that engage in specified business, activities and/or transactions involving Syria that may be more restrictive than U.S. federal sanctions after the issuance of GL 25. Companies seeking to take advantage of new opportunities in Syria may consider reviewing relevant contractual restrictions to which they or their parent company(ies) (including fund managers) and/or affiliates may be subject to ensure that legally permissible, Syria-related business does not result in a breach thereof.