U.S. Lifts Comprehensive Sanctions Against Syria and Paves the Way for Modifications to Applicable Export Controls

On June 30, 2025, President Trump issued an Executive Order (“EO”) “Providing for the Revocation of Syria Sanctions” (the “Syria EO”) and an accompanying fact sheet. The Syria EO effectively lifts the comprehensive sanctions against Syria, while maintaining and expanding list-based sanctions against certain individuals, including former Syrian President Bashar al-Assad and others associated with his regime.

Concurrent with the issuance of the Syria EO, the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”) issued a press release and Frequently Asked Question (“FAQ”) guidance on the Syria EO and related follow-on measures. OFAC also announced that it will remove the Syrian Sanctions Regulations (“SySR,” 31 CFR part 542) from the Code of Federal Regulations, and that OFAC’s Syria-related sanctions program will now become the Promoting Accountability for Assad and Regional Stabilization Sanctions (“PAARSS”) program.

These steps follow President Trump’s May 13 statement that he would order the “cessation of sanctions against Syria,” and OFAC’s subsequent issuance on May 23 of General License (“GL”) 25. GL 25 broadly authorized, subject to certain exceptions: (1) transactions that would otherwise be prohibited under the SySR 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. OFAC has confirmed that GL 25 remains in effect and can continue to be relied on for activities it authorizes otherwise prohibited by other sanctions programs (i.e., programs other than the now-rescinded SySR). For more on GL 25, see our prior alert.

The Syria EO also declared the waiver of certain statutorily imposed sanctions and export controls with respect to Syria, as is permitted under the relevant statutes, and directed the Secretary of State to submit certain required reports regarding the waivers to the appropriate congressional committees.

As part of the coordinated action, Secretary of State Marco Rubio issued a statement and the State Department provided a fact sheet concerning the end of the Syria sanctions program. While it is expected that the U.S. Commerce Department, Bureau of Industry and Security (“BIS”) will modify the Export Administration Regulations (“EAR”) to ease the restrictions on exports, reexports, and transfers to and within Syria of items subject to the EAR, this has not yet happened. Thus, with the exception of qualified EAR99 food and medicine, all items subject to U.S. jurisdiction under the EAR continue to require BIS authorization for export, reexport, or transfer to or within Syria.

Effects on Syria-Related Sanctions

The Syria EO revokes six prior EOs that formed the basis of the comprehensive U.S. sanctions against Syria and terminates the national emergency under which those EOs were issued. In FAQ guidance, OFAC stated that, as a result of the revocation of these six EOs, “the economic sanctions administered by OFAC that constitute the Syria Sanctions Program are no longer in effect” (see OFAC FAQ 1220). OFAC also announced that it will remove the SySR from the Code of Federal Regulations, and that OFAC’s Syria-related sanctions program will now become the PAARSS program. OFAC also announced that it had removed 518 individuals and entities from the List of Specially Designated Nationals and Blocked Persons (“SDN List”) that were sanctioned under the Syria sanctions program. However, OFAC stated that it may continue to carry out pending or future investigations or enforcement actions related to apparent violations of the SySR that occurred before July 1, 2025.

While the Syria EO removes the comprehensive sanctions on Syria, it maintains certain list-based sanctions on Bashar al-Assad, his associates, and other persons or entities involved in certain destabilizing actions in or related to Syria. In particular, the Syria EO amends EO 13894 to expand both the scope of the national emergency declared therein as well as the range of sanctions authorized under that EO. OFAC also subsequently designated to the SDN List 139 individuals and entities affiliated with the Assad regime or engaged in other sanctionable activities pursuant to EO 13894, as amended, as well as other Iran and Counter Terrorism authorities. These designations include certain persons who were previously sanctioned under the SySR.

Implications for Existing Export Controls

While the Syria EO does not itself lift the export controls in place with respect to Syria, it paves the way for such export controls to be lifted in the future in compliance with statutory requirements. Certain export controls targeting Syria have been imposed through acts of Congress, and thus any modifications to such export controls must comply with those statutes, absent additional legislative action. The two most significant pieces of legislation imposing export controls on Syria are the Syria Accountability and Lebanese Sovereignty Restoration Act of 2003 (“Syria Accountability Act”) and the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (“CBW Act”).

Both the Syria Accountability Act and the CBW Act prohibit the export to Syria of certain national security-sensitive goods and technologies (see Syria Accountability Act § 5(a)(1); CBW Act § 307(a)(5)), and potentially prohibit the export of all goods and technologies to Syria, excluding food, depending on what other restrictions are concurrently imposed on Syria (see Syria Accountability Act § 5(a)(2)(A); CBW Act § 307(b)(2)(C)).

However, both statutes allow for these export control requirements to be waived if the President makes certain determinations (see Syria Accountability Act § 5(b); CBW Act § 307(d)(1)). The Syria EO makes the necessary determinations, and waives the relevant export control requirements, under both the Syria Accountability Act and the CBW Act.

Notably, waivers under section 307(d)(1)(B) of the CBW Act may only take effect 20 days after they are officially transmitted to Congress, which is reflected in the language of the Syria EO. There is no similar waiting period under the Syria Accountability Act. Accordingly, depending on when the Secretary of State officially transmits the CBW Act waiver to Congress, the CBW Act-related export controls on Syria may be lifted 20 days thereafter. We are not aware that such transmission has already occurred, and it is possible that such transmission will not be made public. While BIS has not announced what actions it will take following the waiver period, we expect that those actions will have the effect of easing the restrictions on exports, reexports, and transfers to and within Syria of items subject to the EAR, in line with the Trump Administration’s goal of “giv[ing] Syria a chance to rebuild.”

Impact on Terrorism-Related Designations

The current President of Syria, Ahmed al-Sharaa, is also the leader of Hayat Tahrir Al-Sham (“HTS”), the group that led the overthrow of the previous Assad regime. Both Ahmed al-Sharaa and HTS have been designated to OFAC’s SDN List as Specially Designated Global Terrorists (“SDGTs”) pursuant to sanctions authorities that are independent of the Syria sanctions. HTS also is designated by the State Department as a Foreign Terrorist Organization (“FTO”), which implicates certain criminal statutes targeting material support for terrorism, and the country of Syria is designated as a State Sponsor of Terrorism (“SST”), which also implicates certain export controls and sanctions.

The Syria EO directs the Secretary of State to take all appropriate action with respect to the designation of HTS as an FTO and as an SDGT, as well as with respect to the designation of Ahmed al-Sharaa as an SDGT. It also directs the Secretary of State to take all appropriate action to review Syria’s designation as an SST. However, the Syria EO does not provide a timeline or detailed requirements for the removal of these designations.

Syria-Related Sanctions Legislation

As discussed in our prior client alert, the Syria Accountability Act and the Caesar Syria Civilian Protection Act of 2019 (“Caesar Syria Act”) require the imposition of certain sanctions with respect to Syria. Because certain restrictions required by the Syria Accountability Act remain in effect (e.g., a prohibition on any aircraft owned or controlled by Syria from entering the United States and certain restrictions on Syrian diplomatic operations and travel in the United States) the requirements of the Syria Accountability Act continue to be met, notwithstanding the Syria EO’s lifting of comprehensive sanctions.

With regard to the Caesar Syria Act, the State Department’s 180-day waiver of the secondary sanctions required under that Act, issued on May 23, 2025 alongside GL 25, continues in effect. Moreover, the Syria EO directs the Secretary of State to determine whether the conditions for suspending the Caesar Syria Act sanctions have been met, as outlined in section 7431(a) of the Act. However, under the Caesar Syria Act, both waivers and suspensions are only valid for renewable 180-day periods. The requirement for the affirmative renewal of waivers and/or suspensions of sanctions under the Act may serve as a check on the activities of the new Syrian government, pending further legislative or other action.

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