On May 23, 2025, the Trump Administration took a series of steps to substantially ease the comprehensive U.S. sanctions against Syria. These actions follow President Trump’s May 13 announcement that he would order “the cessation of sanctions against Syria” in light of the changing political landscape following the collapse of Bashar al-Assad’s government on December 8, 2024. European Union and United Kingdom authorities also recently pursued similar actions to ease sanctions they previously adopted against Syria.
Specifically, the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”) issued General License 25 (“GL 25”), broadly authorizing, subject to certain exceptions: (1) transactions that would otherwise be prohibited under the Syrian Sanctions Regulations (“SySR,” 31 CFR part 542), other than transactions involving blocked persons; and (2) transactions that would otherwise be prohibited by the SySR and/or various other identified sanctions programs with certain blocked persons, i.e., the Government of Syria, persons identified in the Annex to GL 25 (“Annex-listed Persons”), and entities owned 50 percent or more (directly or indirectly) by one or more Annex-listed Persons.
On May 28, 2025, OFAC published a Fact Sheet containing Frequently Asked Questions (“FAQs”) that provide further guidance related to GL 25, describing the new general license as “effectively lifting sanctions on Syria.” The FAQs include examples of transactions authorized under GL 25, as well as a clarification that previously existing general licenses remain in force.
Notably, the U.S. Commerce Department, Bureau of Industry and Security (“BIS”) has not at this point taken steps to ease the stringent U.S. export controls in place with respect to Syria, such that, with the exception of qualified EAR99 food and medicine, all items subject to U.S. export control jurisdiction continue to require prior specific BIS licensing for export, reexport, or transfer to or within Syria.
Although legislation mandating the imposition of certain Syria-related sanctions remains in force, the relaxation of sanctions under GL 25 is consistent with these statutes. Notably, concurrent with the announcement of GL 25, the U.S. State Department issued a waiver under the Caesar Syria Civilian Protection Act of 2019 (“Caesar Syria Act”). The waiver, which is effective for a renewable 180-day period, removes the secondary sanctions risks for non-U.S. persons engaged in the types of transactions authorized by GL 25.
As an additional step in unwinding the U.S. sanctions on Syria, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network, in coordination with OFAC, issued “exceptive relief” that will permit covered financial institutions to maintain correspondent accounts for the Commercial Bank of Syria under certain conditions.
These steps follow the Biden Administration’s issuance of General License 24 (“GL 24”) in January 2025, which authorizes U.S. persons—through July 6, 2025—to engage in transactions with governing institutions in Syria and in certain transactions related to energy and personal remittances, subject to certain conditions. OFAC’s FAQ guidance explains that GL 25 generally authorizes those transactions previously authorized by GL 24, which will remain in effect until its July expiration (see GL 25 FAQ 4).
Furthermore, on May 27, 2025, the Council of the European Union formalized its decision to lift the majority of sanctions regarding Syria, thereby implementing a political commitment announced by the Council on May 20, 2025. The May 27 action formally revokes previously suspended restrictions and also revokes most of the remaining EU-Syria trade sanctions. The UK Government also recently lifted certain Syria-related sanctions.
Recent U.S. Actions
Scope of Transactions Authorized Under GL 25
GL 25 was issued pursuant to the SySR as well as the following authorities administered by OFAC: the Weapons of Mass Destruction Proliferators Sanctions Regulations (“WMDPSR,” 31 CFR part 544), the Iranian Financial Sanctions Regulations (“IFSR,” 31 CFR part 561), the Global Terrorism Sanctions Regulations (“GTSR,” 31 CFR part 597), the Foreign Terrorist Organizations Sanctions Regulations (“FTOSR,” 31 CFR part 597), and Executive Order 13574 of May 23, 2011 (“E.O. 13574”).
Subject to specific limitations, Section (a) of GL 25 authorizes all transactions prohibited by the SySR other than those involving blocked persons. As confirmed by the corresponding OFAC press release, the transactions authorized by this provision of GL 25 include new investment in Syria, the provision of financial and other services to Syria, and transactions related to Syrian-origin petroleum or petroleum products.
Section (b) of GL 25 authorizes, subject to specific limitations, all transactions prohibited by the SySR, the WMDPSR, the IFSR, the GTSR, the FTOSR, or E.O. 13574 involving the Government of Syria, Annex-listed Persons, and any entity owned, directly or indirectly, 50 percent or more by one or more Annex-listed Persons.
GL 25 specifies that the “Government of Syria” is defined with reference to Section 542.308 of the SySR, and as in existence on or after May 13, 2025. This includes: (1) the state and the Government of the Syrian Arab Republic, as well as any political subdivision, agency, or instrumentality thereof; (2) any entity owned or controlled, directly or indirectly, by an entity described in (1); (3) any person that is, or has been, acting or purporting to act, directly or indirectly, for or on behalf of any entities described in (1) or (2); and (4) any other person determined by OFAC to be included within (1)-(3). A note to GL 25 provides expressly that the “Government of Syria includes Syrian President Ahmed al-Sharaa and his government.”
The Annex-listed Persons include individuals and entities that will be instrumental to any rebuilding of Syria. The list includes Abu Muhammad Al-Jawlani (also known as Ahmed al-Sharaa, the President of Syria), Anas Hasan Khattab (Syria’s Minister of the Interior), the Central Bank of Syria, Sytrol, General Petroleum Corporation, and Syrian Arab Airlines, among others.
OFAC’s FAQ guidance provides examples of transactions authorized under GL 25, provided the activities otherwise satisfy the authorization. These include, for instance, telecommunications-related services; power grid infrastructure rehabilitation and other energy-related services; health care-related services; civil aviation and other transportation services; construction-related services; water and waste management-related services; and financial and investment services (see GL 25 FAQ 1). The guidance also states that U.S. banks are authorized to process transactions for any activities authorized by GL 25.
OFAC also makes clear in its FAQ guidance that previously issued general licenses that may be related to activity in Syria, such as those authorized under the GTSR and/or the FTOSR, continue in effect. Examples of activities authorized under such general licenses include transactions in support of certain nongovernmental organizations’ activities (31 CFR sections 594.520, 597.516), official business of the U.S. Government (31 CFR sections 594.518, 597.514), and official business of certain international organizations (31 CFR sections 594.519, 597.515) (see GL 25 FAQ 8). The FAQ guidance explains that, with respect to transactions in support of certain nongovernmental organizations’ activities, U.S. depository institutions, U.S. registered brokers or dealers in securities, and U.S. registered money transmitters can rely on the statements of their customers that a transaction is authorized, unless they know or have reason to know otherwise. Furthermore, OFAC GL 25 FAQ 8 emphasizes that where multiple authorizations may apply, U.S. persons may rely on the broadest applicable authorization.
GL 25 also expressly excludes from its scope certain activities. Section (c) of GL 25 clarifies that GL 25 does not authorize transactions involving any individual or entity identified on OFAC’s List of Specially Designated Nationals and Blocked Persons (“SDN List”) that is not an Annex-listed Person, or any entity owned, directly or indirectly, individually or in the aggregate, 50 percent or more by an Annex-listed Person. GL 25 also does not authorize the unblocking of any property or interests in property blocked pursuant to OFAC’s sanctions programs as of May 22, 2025. Finally, GL 25 does not authorize any transaction 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, nor any transaction related to the transfer or provision of goods, technology, software, funds, financing, or services to or from any of these jurisdictions.
Additionally, GL 25 does not authorize transactions prohibited by the laws or requirements of other federal agencies, including the Export Administration Regulations (“EAR”) administered by BIS and the International Traffic in Arms Regulations (“ITAR”) administered by the State Department. The ITAR continue to broadly prohibit unauthorized defense trade activities with Syria. The EAR prohibit, absent separate licensing or authorization from BIS, the export, reexport, or transfer to or within Syria by any person of goods, technology, or software that are subject to the regulatory jurisdiction of the EAR, other than qualified food and medicine that are classified as EAR99. BIS has not yet taken any action to ease these export control restrictions with respect to Syria. Of note, Syria remains a designated State Sponsor of Terrorism (“SST”), a designation that requires Congressional notification to remove (see Section 1754(c)(4) of the National Defense Authorization Act for Fiscal Year 2019; Section 40(f) of the Arms Export Control Act of 1976; and Section 620A(c) of the Foreign Assistance Act of 1961). Countries designated as SSTs are subject to statutorily mandated export controls. So long as Syria remains an SST, the Trump Administration’s ability to relax export controls on Syria will be limited.
Implications for Existing Sanctions on Hayat Tahrir Al-Sham
As noted, GL 25 specifically states that the Government of Syria includes Syrian President Ahmed al-Sharaa and his government. Importantly, Ahmed al-Sharaa is the leader of Hayat Tahrir Al-Sham (“HTS”), the group that led the overthrow of the Assad regime. HTS is designated to the SDN List pursuant to terrorism-related sanctions authorities that are independent of the Syria sanctions—i.e., the GTSR and FTOSR. HTS also is designated by the State Department as a Foreign Terrorist Organization, which implicates certain criminal statutes targeting material support for terrorism. HTS is not listed in the Annex of GL 25, nor has OFAC removed HTS from the SDN List. Accordingly, even as GL 25 authorizes certain transactions with the Government of Syria, including Syrian President Ahmed al-Sharaa and his government, it does not authorize transactions with or material support to or for HTS.
Relationship of GL 25 to Syria-Related Sanctions Legislation
Sanctions and export controls targeting Syria have been imposed not only through executive and administrative actions but also by acts of Congress. Although OFAC has the authority to amend its own sanctions-related regulations and issue licenses, modifications to the sanctions imposed through legislation would need to comply with the text of those statutes, absent additional legislative action. The two most significant pieces of such legislation are the Syria Accountability and Lebanese Sovereignty Restoration Act of 2003 (“Syria Accountability Act”) and the Caesar Syria Act.
Syria Accountability Act
The Syria Accountability Act, enacted on December 12, 2003, requires that the President impose a variety of sanctions and export controls on Syria. Section 5(a)(1) of the Act requires the President to prohibit the export to Syria of any item, including the issuance of a license for the export of any item, on the EAR’s Commerce Control List or the ITAR’s U.S. Munitions List. Additionally, Section 5(a)(2) of the Act sets out a list of six types of sanctions and requires the President to impose two or more of the six. The six types of sanctions described under the statute are:
1. Enacting a trade embargo of Syria;
2. Prohibiting U.S. company investment or operations in Syria;
3. Restricting travel in the United States by Syrian diplomats;
4. Prohibiting aircraft of any air carrier owned or operated by Syria to take off from, land in, or fly over the United States;
5. Reducing U.S. diplomatic contacts with Syria; and
6. Imposing property-blocking sanctions on the Government of Syria.
The flexible nature of Section 5(a)(2) allows for the relaxation of certain sanctions without implicating the statute. Although GL 25 effectively authorizes new investment in Syria and transactions involving the Government of Syria and certain other blocked parties, certain other restrictions remain in effect, e.g., a prohibition on any aircraft owned or controlled by Syria from entering the United States (see 14 CFR part 91, Special Federal Aviation Regulation No. 104) and certain restrictions on Syrian diplomatic operations and travel in the United States (see Press Release, Travel Restrictions Placed on Syrian Ambassador; Press Release, Statement by Special Envoy for Syria on Suspension of Syrian Embassy Operations). As at least two of the six required sanctions remain in effect, the Administration appears to continue to meet the statutory requirements of the Syria Accountability Act, notwithstanding the issuance of GL 25.
The Syria Accountability Act also allows the President to: (1) waive all of the foregoing sanctions and export controls if he determines that it is in the interest of U.S. national security to do so and submits to the appropriate congressional committees a report containing the reasons for the determination; and (2) terminate the foregoing sanctions and export controls upon certifying to the appropriate congressional committees a determination that the Government of Syria has ceased certain activities with respect to support for terrorism, its occupation of Lebanon, and WMD and missile proliferation. Thus, in the future, President Trump could take one of these steps to more fully dispense with the sanctions and export controls requirements of the Syria Accountability Act.
Caesar Syria Act
The Caesar Syria Act, which came into force on June 17, 2020, prescribes additional mandatory sanctions related to Syria. Section 7412(a) of the Act requires the President to impose secondary sanctions on non-U.S. persons that engage in certain transactions with or related to the Government of Syria. Required secondary sanctions include full property-blocking sanctions and making designated foreign persons ineligible for visas, admission, or parole to the United States.
Under Section 7432(b) of the Act, if the President certifies to the appropriate congressional committees that a waiver is in the national security interests of the United States, the required sanctions on foreign persons may be waived for renewable periods not to exceed 180 days. As noted, concurrent with the issuance of GL 25, the State Department released a press statement announcing that it had issued a 180-day waiver of mandatory Caesar Syria Act sanctions in accordance with Section 7432(b) of the Act.
Recent EU and UK Actions
EU Sanctions
On May 27, 2025, the Council of the European Union formalized its decision to lift the majority of sanctions regarding Syria, thereby implementing a political commitment announced by the Council on May 20, 2025. This follows measures implemented by the EU on February 24, 2025, to partially suspend certain elements of its Syria sanctions regime.
Implemented through Council Regulation (EU) 2025/407, the February suspension eased several restrictions under the principal EU-Syria sanctions regulation (Council Regulation (EU) No 36/2012), including:
- Import bans on Syrian crude oil and petroleum products;
- Export restrictions on equipment and technology for Syria’s oil and gas sector;
- Export bans on jet fuel and fuel additives to Syria;
- Prohibitions on the sale of equipment and provision of technical services for constructing new electricity-generating power plants in Syria; and
- Investment restrictions in Syria’s energy sector.
Several Syrian financial institutions were also removed from the EU asset-freezing list at that time, including the Industrial Bank, Popular Credit Bank, Saving Bank, and Agricultural Cooperative Bank.
Council Regulation (EU) 2025/1098, adopted on May 27, 2025, formally revokes the previously suspended restrictions and also revokes most of the remaining EU-Syria trade sanctions, including restrictions:
- on the export of gold, precious metals, diamonds, and luxury goods;
- on selling or purchasing Syrian public or public-guaranteed bonds issued after January 19, 2012;
- on establishing banking relations between Syrian banks and EU financial institutions;
- on providing insurance and reinsurance services to the Syrian government;
- on access to EU airports by cargo flights operated by Syrian carriers and all flights operated by Syrian Arab Airline; and
- that prevented the European Investment Bank (“EIB”) from making disbursements or payments under existing loan agreements with the Syrian state.
While restrictions concerning the export and import of Syrian cultural property goods formally remain, the regulation removed Annex XI—which listed the affected products—effectively suspending these restrictions.
Following the lifting of these restrictions, the EU-Syria sanctions regulation retains targeted export restrictions limited to:
- Goods related to internal repression, as listed in Annex IA and Annex IX, encompassing certain dual-use items, including specific chemicals and substances;
- Monitoring or interception goods listed in Annex V; and
- Services associated with the foregoing restricted goods.
On May 27, 2025, the Council also adopted Council Implementing Regulation (EU) 2025/1094, amending the list of parties subject to asset-freezing sanctions under the Syria sanctions regime. This regulation removes additional Syrian parties from the EU asset-freezing list, although a significant number of individuals and entities remain designated, particularly those associated with the former Assad regime. Additionally, the Ministry of Defence and Ministry of Interior continue to be subject to asset-freezing sanctions. However, the regulation introduces a licensing provision permitting EU Member States to issue licenses for engagement with these ministries if intended for cooperation in reconstruction, capacity-building, counter-terrorism, and migration efforts.
Moreover, it appears that the EU has intended to lift asset-freezing sanctions against the Commercial Bank of Syria and Central Bank of Syria. This intention is reflected in both the Council’s press statements and the accompanying Council Decision, and amendments to Regulation 36/2012. The latest amendments retain in Regulation 36/2012 the annexes that the Commercial Bank of Syria and Central Bank of Syria are designated under (Annex IIa and IIb), which we expect is simply a legislative oversight. Notably, those annexes were removed from the accompanying Council Decision, and the operative provisions of Regulation 36/2012 imposing sanctions on parties designated under Annexes IIa and IIb have been removed.
Finally, we note that HTS and Syrian President Ahmed al-Sharaa, designated under the EU’s sanctions regime targeting individuals and entities associated with ISIL (Da’esh) and Al-Qaida, remain subject to EU asset-freezing sanctions. The EU has not provided guidance on the extent to which the continued listing of Ahmed al-Sharaa or HTS affects dealings with the Syrian government. It is clear from the overall context of the measures described above (and accompanying EU press statements) that the Council does not view the Government of Syria to be subject to asset-freezing measures (apart from specially designated agencies thereof). However, EU asset-freezing sanctions would, under general EU sanctions principles, presumptively extend to entities and assets that Ahmed al-Sharaa or HTS hold a 50 percent or greater interest in or otherwise control.
UK Sanctions
The EU measures described above follow similar actions implemented by the UK Government, in March and April 2025, to lift most aspects of the UK trade sanctions against Syria, and to remove various Syrian parties from the UK asset-freezing list. The UK-Syria sanctions, as amended, are set out in the Syria (Sanctions) (EU Exit) Regulations 2019.
The remaining UK-Syria trade sanctions include trade controls restrictions on certain security-sensitive goods (consistent with the remaining EU measures noted above), restrictions on the export of certain luxury goods to Syria, restrictions on transactions with the Syrian governing authorities concerning diamonds and certain precious metals, and restrictions on bonds issued by the Assad regime.
As with regard to the EU sanctions, HTS remains a proscribed terrorist organisation in the UK and is still subject to UK asset freezing sanctions, as is Syrian President Ahmed al-Sharaa. In December 2024, UK Prime Minister Sir Kier Starmer stated that it was “too early” to reconsider the proscription of HTS as a terrorist organisation—Foreign Secretary David Lammy indicated that the UK would judge HTS “by [their] actions” before taking any steps to remove the designation of HTS.
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We are closely monitoring developments concerning U.S., EU, and UK sanctions and export controls and will issue further updates in the event of material developments. In the meantime, we would be happy to address any questions you may have.
Covington’s International Trade Controls team—which includes lawyers in the firm’s offices in the United States, London, and Frankfurt—regularly advises clients across business sectors, and would be well-placed to provide support in connection with the changing landscape of U.S. sanctions and export controls on Syria. Our trade controls lawyers also work regularly with Covington's Global Public Policy team—consisting of over 120 former diplomats and policymakers in the United States, Europe, the Middle East, Latin America, Africa, and Asia—many of whom have had substantial government experience in sanctions and export controls matters, and who regularly advise our clients on emerging sanctions policy matters and related engagements with government stakeholders.
If you have any questions concerning the material discussed in this client alert, please contact the members of our International Trade Controls practice.
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