Lifting of Sanctions on Syria by the United States, European Union, and United Kingdom

In recent weeks, the United States, European Union, and United Kingdom have taken significant steps to relax of their sanctions on Syria, paving the way for long-awaited normalization of commercial relations and reconstruction following the country’s civil war. The actions—which follow pledges of financial assistance and expressions of interest in economic investment among key Gulf Cooperation Council (“GCC”) and G20 countries—provide immediate relief and open the door to investment, trade and humanitarian activity subject to important legal and practical limitations that parties should bear in mind in planning Syria-related activities.

Earlier this month, US President Donald Trump announced his intention to lift certain sanctions on Syria. Accordingly, the Trump Administration has taken concrete steps to begin easing restrictions. Notably, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued General License No. 25 (“GL 25”), the US State Department granted a waiver under the Caesar Syria Civilian Protection Act of 2019 (“Caesar Act”), and the Financial Crimes Enforcement Network (“FinCEN”) provided exceptive relief allowing US financial institutions to maintain correspondent accounts for the Commercial Bank of Syria.

The European Union, which has maintained narrower and more targeted sanctions than the United States, began easing sanctions against Syria in February 2025. On May 20, the EU announced that it would lift the remaining sanctions, and the legal instruments formalizing this decision were adopted on May 28, 2025.

Likewise, the United Kingdom began lifting sanctions on key companies within the Syrian economy in March 2025. In April 2025, the UK introduced legislation to amend and revoke measures targeting, among other areas, the transport, trade, energy, and finance sectors of the Syrian economy.

We provide below a summary of what has changed across the US, EU, and UK regimes, what remains, and the practical considerations for trading partners, investors and humanitarian organizations.  

1. Key Changes & Practical Considerations

1.1 What Has Changed

Expanded Business Opportunities – US parties (not time-limited) and non-US parties (currently for 180 days) can now conduct business with the current Syrian government, as well as with certain previously blocked actors listed in GL 25, including Syria’s core financial institutions, such as the Central Bank of Syria and the Commercial Bank of Syria.

The EU and UK are similarly opening up opportunities, but with ongoing restrictions for certain actors and sectors.

Scope of Relief – The easing of US sanctions covers many sectors of the Syrian economy, but does not permit transactions involving terrorist organizations, human rights violators, drug traffickers, or the former Assad regime. The United States has also dictated that transactions involving Syria that benefit Russia, Iran, or North Korea remain prohibited. Moreover, US export controls and other federal requirements still apply. Dealings with Specially Designated Nationals (“SDNs”) not listed in GL 25 remain prohibited.

In parallel, the EU and UK will continue to enforce asset freezes and travel bans on parties related to the former Assad regime members and other designated individuals and entities, while maintaining sectoral sanctions based on security grounds.

1.2 Practical Considerations For Businesses

The United States, EU, and UK started easing sanctions on Syria, creating new opportunities for trade and investment. However, significant restrictions remain, and the risk of rapid policy changes persists. Businesses engaging in Syria should remain vigilant, ensure robust compliance, and monitor ongoing developments in all relevant jurisdictions.

Comprehensive Due Diligence – These changes eliminate the broad sanctions that previously prohibited nearly all activities involving Syria, including those related to new investments and provision of services. As a result, new business opportunities are now available. However, it remains essential to conduct comprehensive due diligence on all counterparties and transaction participants to ensure compliance with ongoing restrictions, particularly those involving US embargoed countries, as well as SDNs and/or parties subject to EU or UK sanctions. Furthermore, exporters/reexporters of items subject to US export controls, as well as operators that remain subject to EU or UK export controls, must continue to comply with license requirements absent additional regulatory developments.

Compliance Updates – Companies should update Know Your Customer (“KYC”) protocols, contractual terms, and compliance frameworks to reflect the new landscape.

Snapback Risk – All three jurisdictions have emphasized that sanctions relief is reversible and subject to change based on developments in Syria. Businesses should monitor for potential policy reversals.

Statute of Limitations – The lifting of sanctions does not retroactively legalize past violations; enforcement remains possible for prior conduct.

Potential Divergences – While the United States, EU, and UK have taken steps to lift sanctions against Syria, such lifting can vary in scope with differing time frames, resulting in potential divergences between US, EU, and UK sanctions regimes, which are likely to create a complex compliance environment. Businesses must monitor developments closely and ensure compliance with all applicable regimes, as the easing of restrictions in one jurisdiction does not automatically permit activities under another.

2. US Sanctions on Syria: Relief Granted And Other Restrictions

Since 2011, the US government has maintained a comprehensive embargo on Syria. The sanctions regime on Syria is multilayered, comprising executive orders, statutory sanctions (notably the Caesar Syria Civilian Protection Act, or the “Caesar Act”), and designations under the State Sponsor of Terrorism (“SST”) framework. Recent developments, such as OFAC GL 25, FinCen’s issuance of exceptive relief for the Central Bank of Syria, and the State Department’s waiver of secondary sanctions, represent significant steps towards easing restrictions. Nevertheless, significant limitations remain in effect, and the overall sanctions framework continues to impose certain restrictions.

2.1 Relief Granted

OFAC General Licenses 25 – GL 25 authorizes all transactions that would otherwise be prohibited under the Syrian Sanctions Regulations, with certain exceptions. Specifically, the license only authorizes transactions with the entities listed in the Annex to GL 25. Dealings with SDNs not listed remain prohibited. Furthermore, the authorization extends to transactions with any entity in which one or more of the blocked persons listed in the Annex own, directly or indirectly, individually or in the aggregate, a 50% or greater interest.

The Annex identifies a range of Syrian government ministries, financial institutions, and state-owned enterprises, including but not limited to:

• Syrian Arab Airlines
• Commercial Bank of Syria
• Central Bank of Syria
• General Petroleum Corporation
• Syrian Gas Company
• Syrian Ministry of Tourism

GL 25 also does not unblock any property or interests in property that were blocked as of May 22, 2025, nor does it authorize any transactions for or on behalf of the Government of Russia, Iran, or North Korea or transactions related to the transfer or provision of goods, technology, software, funds, financing, or services to or from Iran, Russia, or North Korea. Furthermore, the general license does not relieve any person from compliance with other federal laws or requirements of other federal agencies, including the International Traffic in Arms Regulations (the “ITAR”) and the Export Administration Regulations (the “EAR”).

State Department Secondary Sanctions Waiver – Under the Caesar Act, the US government can impose secondary sanctions on non-US parties engaging in certain transactions with the Government of Syria. The State Department waived these sanctions for 180 days to allow non-US parties to make stability-driving investments and advance Syria's recovery and reconstruction efforts.

FinCen Exceptive Relief against Central Bank of Syria – FinCEN provided exceptive relief to permit US financial institutions to maintain correspondent accounts for the Commercial Bank of Syria. This is a practical step that will enable the reestablishment of financial channels and support the broader economic reopening of Syria.

2.2 Other Restrictions

Sanctions Risks – The lifting of sanctions against Syria, while prompted by a change of regime and the willingness to support the Syrian population, does not mean that the United States, the EU, and the UK no longer have any concerns about the current political situation. Significantly, OFAC issued a general license and the State Department issued a temporary waiver and did not repeal the underlying regulations. Depending on the evolution of the situation on the ground, sanctions could be reintroduced and adequate measures should be implemented to preempt that risk.

Blocked Persons – Transactions involving SDNs not listed in the Annex to GL 25 remain prohibited.

Export Control Restrictions – The Syria Accountability Act (the “SAA”) imposes broad export control restrictions on Syria. As a direct result of the SAA, the United States maintains stringent export and reexport controls on Syria. This means that virtually all items subject to the EAR—goods, technology, and software (except for EAR99 food and medicine)—must have prior US government authorization before they can be sent to Syria.

State Sponsor of Terrorism – Syria has been designated a State Sponsor of Terrorism since December 1979. This designation entails restrictions on US foreign assistance; a ban on defense exports and sales; certain controls over exports of dual use items; and miscellaneous financial and other restrictions. Removal of the SST designation requires State Department and Congressional action.

3. EU Sanctions: Relief Granted and Continuing Restrictions

Following the fall of the Assad regime, the EU initiated a process to lift sanctions against Syria, adopting a staged and reversible approach to the suspension of these restrictive measures. The first stage was implemented through legal instruments that entered into force on February 26. Subsequently, Decision 2025/1095, Decision 2025/1096, Regulation 2025/1094 and Regulation 2025/1098 were adopted on May 28, 2025 and will enter into force on May 29, 2025. Through these measures, the EU lifted most sanctions targeting Syria, while maintaining those related to the Assad regime, and those imposed on security grounds. However, the lifting of these sanctions remained contingent upon the evolution of the situation in Syria, with the possibly of reimposing measures (snapbacks).

3.1 Amendments To Asset Freeze Measures

Amended grounds for designation – The EU made limited amendments to the grounds for designation, in order to clarify that asset-freeze measures may continue to be imposed on target individuals and entities linked to the former Assad regime.

New derogation specific to the Syrian Ministry of Defense and Ministry of Interior – While those two ministries remain subject to asset-freeze measures, authorizations may be obtained where necessary for the cooperation between those entities and a Member State’s governmental entity or body in the areas of reconstruction, capacity-building, counterterrorism and migration.

National competent authorities will have five working days to request information, notify  additional time or reject the authorization, failing which the authorization will be considered granted.

Lifting of asset freeze measures – The EU lifted asset-freeze measures against 24 entities, namely banks and entities operating in the oil production and refining, cotton, telecommunications and media sectors. The EU notably lifted the partial asset-freeze measures against the Central Bank of Syria, which had remained following the earlier February 2025 easing of sanctions against Syria.

Introducing new asset freeze measures – In parallel, the EU announced the imposition of sanctions against two individuals and three entities under the EU’s global human rights sanctions regime, in connection with the wave of violence that took place in Syria’s coastal region in March 2025.

3.2 Amendments to Sectoral Sanctions

Termination of measures that had been suspended in February 2025 – Sectoral sanctions that had already been suspended in February 2025, mostly concerning the energy and transport sectors, have been terminated.

Trade-related restrictions lifted – The EU lifted the trade-related restrictions targeting (i) gold, precious metals and diamonds (import- and export-related) and (ii) luxury goods (export-related).

In addition, while import- and export-related restrictions are maintained on Syrian cultural property goods and other goods of archaeological, historical, cultural, rare scientific or religious importance, the list contained in Annex XI of Regulation 36/2012 has been removed.

Financial services restrictions lifted – The EU has lifted its restrictions relating to financial services, namely:

• Restrictions on specific financing activities carried out by the European Investment Bank.
• Restrictions targeting Syrian public or public-guaranteed bonds issued after January 19, 2012.
• Restrictions limiting the relationships between EU credit and financial institutions with Syrian credit and financial institutions, as well as the ability of EU credit and financial institutions to open new representative offices, branches or subsidiaries in Syria.
• Restrictions limiting the presence of Syrian credit and financial institutions in the EU through representative offices, branches, subsidiaries, authorizations or acquisition of ownership interest in EU credit and financial institutions.
• Restrictions on the provision of insurance or reinsurance to the State of Syria, its Government, its public bodies, corporations or agencies, or any individual or entity acting on its behalf or at its direction.

Lifting of restrictions on Member States – Restrictions imposed on Member States with regard to financial support for trade with Syria and on commitments for grants, financial assistance or loans to the Government of Syria have also been lifted.

3.3 What Remains?

While the scope of sanctions that have been lifted is substantial, not all sanctions against Syria have been terminated.

The EU notably maintains asset-freeze measures targeting individuals and entities related to the Assad regime, the chemical weapons sector and illicit drug trade.

The EU also maintains sectoral-restrictive measures based on security grounds, namely trade-related restrictions on: (i) arms and related materiel of all types; (ii) internal repression items; (iii) internet or telephone communications monitoring or interception items; and (iv) Syrian cultural property goods and other goods of archaeological, historical, cultural, rare scientific or religious importance.

Furthermore, Syria remains on the FATF’s grey list and the EU’s high-risk third-countries list for anti-money laundering purposes.

4. UK Sanctions: Recent Actions

The UK has taken a similar staged and reversible approach to the lifting of sanctions against Syria. The UK Government has stated that its strategy is designed to help the Syrian people rebuild and promote security and stability while ensuring that “asset freezes and travel bans imposed on members of the former regime remain in force.”

On March 6, the UK lifted sanctions on 24 entities to help “the people of Syria rebuilding their country and economy.” This included the lifting of sanctions on the Central Bank of Syria, the Commercial Bank of Syria, the Syrian Arab Airlines and certain Syrian energy companies. On April 24, the UK lifted sanctions on further entities, including the Syrian Ministry of Defense and Ministry of Interior. At the same time, the UK also introduced the Syria (Sanctions) (EU Exit) (Amendment) Regulations 2025, which revoked measures targeting certain sectors of the Syrian economy, including transport, trade, energy and finance.

5. Conclusion

The United States, EU, and UK have announced the lifting of certain sanctions on Syria, marking a significant shift with broad implications. The United States has issued OFAC GL 25, a 180-day waiver of the Caesar Act sanctions, and FinCEN exceptive relief, immediately expanding authorized transactions with the Syrian government and related entities. In parallel, the EU and UK have granted significant relief under their own sanctions targeting Syria. These measures are an initial step toward a new US, EU, UK and Syria relationship, but as for the United States, further executive and legislative action is needed for a complete lifting of restrictions.

All three jurisdictions have emphasized that these changes are reversible, and differences in the scope and timing of sanctions relief may create a complex compliance environment. Businesses should closely monitor developments and ensure compliance with all relevant regimes, as easing in one jurisdiction does not guarantee authorization in another. Ongoing vigilance is essential as the situation evolves.