The US government signals careful optimism with a new general license authorizing some previously prohibited transactions, including many (but not all) transactions with Syrian governing institutions, for the next six months.

After a month of speculation about how US sanctions policy will treat the new leaders of Syria who swept into power in early December and sent Bashar al-Assad into exile, the US Department of Treasury’s Office of Foreign Assets Control (OFAC) has issued General License 24 under the Syria Sanctions Regulations (SySR), the Global Terrorism Sanctions Regulations (GTSR), and the Foreign Terrorist Organizations Sanctions Regulations (FTOSR) on January 6. With certain exceptions, the license temporarily authorizes:

1. Transactions with governing institutions in Syria following December 8, 2024.
2. Transactions in support of the sale, supply, storage, or donation of energy, including petroleum, petroleum products, natural gas, and electricity, to or within Syria.
3. Transactions that are ordinarily incident and necessary to processing the transfer of noncommercial, personal remittances to Syria, including through the Central Bank of Syria.

The license, which currently expires July 7, covers transactions that would otherwise be prohibited not only by the SySR, but also by the GTSR and the FTOSR, given that the new leaders of Syria are part of Hay’at Tahrir al-Sham (HTS), which currently remains a designated terrorist group under those other sanctions programs.

What Is NOT Authorized?

General License 24 does not cover:

1. Financial transfers to any person blocked pursuant to the GTSR, FTOSR, or SySR other than for (i) paying taxes, fees, or import duties to Syrian governing institutions; (ii) paying the wages of Syrian governing institution employees provided they are not listed on OFAC’s Specially Designated Nationals and Blocked Persons (SDN) List; or (iii) purchasing/receiving permits, licenses, public utility services, or other public services in Syria.
2. The unblocking of any property that has already been blocked pursuant to US sanctions regulations.
3. Any transactions involving military or intelligence entities, or any persons acting on their behalf.
4. Importation of Syrian-origin petroleum or petroleum products into the United States.
5. Any transactions for or on behalf of the Government of the Russian Federation or the Government of Iran or related to the transfer or provision of Iranian- or Russian-origin goods, technology, software, funds, financing, or services.
6. New investments in Syria (which OFAC broadly defines as a commitment or contribution of funds or other assets or a loan or extension of credit), except contributions for salaries or wages of Syrian governing institution employees who are not listed on the SDN List.

The bottom line is: except for the three specific categories of authorized activities, all previous economic sanctions concerning Syria still apply. We also think it is wise to assume that it remains prohibited to facilitate any of the activities listed above that are specifically carved out of General License 24’s authorization. Additionally, those seeking to export commodities, software, or technology to Syria must still follow the Syria-specific requirements in the Export Administration Regulations implemented by the US Department of Commerce’s Bureau of Industry and Security.

Helpful New FAQs

Along with the new general license, OFAC released several new FAQs that give some much-appreciated clarity to the state of economic sanctions against Syria. Our top takeaways from the OFAC answers are:

• The purpose of General License 24 is ensuring that US sanctions “do not impede essential governance-related services in Syria following the fall of Bashar al-Assad on December 8, 2024, including for the provision of public services or certain transactions related to energy or personal remittances” (FAQ 1205).
• General License 24 authorizes transactions with a governing institution (with the exceptions noted above), even if it’s operated by a sanctioned individual (FAQ 1208).
• Syrian “governing institutions” are broadly defined to include “departments, agencies, and government-run public service providers (including public hospitals, schools, and utilities) at the federal, regional local level” across all of Syria. (FAQ 1206).
• Previous general licenses, including those that that broadly authorize NGO operations in Syria, are still in effect, and may overlap with General License 24 (FAQs 1212 and 1209).

Conclusions

It appears OFAC will take a wait-and-see approach to decide how to deal with the new HTS-led government in the long term. But for the next six months, General License 24 offers long-awaited sanctions relief (temporary, and carefully circumscribed) for Syria’s new leaders, US persons and entities operating in Syria, and above all, the Syrian people.