The United States has taken a historic step by terminating the Syria Sanctions Program, marking the most significant shift in U.S. foreign policy towards Syria since the fall of the Assad regime. In our earlier post, we outlined the initial steps taken by the U.S., EU, and UK to relax longstanding sanctions on Syria. Since then, the U.S. has introduced additional measures aimed at promoting commercial re-engagement, although several restrictions remain in place. Companies interested in doing business with Syria must stay current on evolving export control, sanctions, and compliance requirements.

Recent U.S. Sanctions Relief Measures

Revocation of Syria Sanctions Program

On June 30, 2025, President Trump issued Executive Order (E.O.) 14312, titled “Providing for the Revocation of Syria Sanctions”.[1] Effective July 1, this order revoked six foundational Executive Orders—including E.O.s 13338, 13399, 13460, 13572, 13573, and 13582—and directed OFAC to remove the Syria Sanctions Regulations (SySR) from the Code of Federal Regulations.

The U.S. government removed over 500 individuals and entities from the OFAC Specially Designated Nationals and Blocked Persons (“SDN”) List and unblocked their property. These removals included major Syrian financial institutions, state-owned energy and shipping companies, military and intelligence agencies, and Syrian Arab Airlines. Despite this broad delisting, approximately 305 Syrian persons and entities remain sanctioned under other authorities.

Notably, General License 25 remains available and continues to authorize certain transactions that are restricted under sanctioned authorities other than the now-revoked SySR.

Continuing and Expanded Sanctions – the “PAARSS” Framework

While the U.S. revoked the comprehensive SySR regime, E.O. 14312 simultaneously expanded and restructured sanctions under E.O. 13894, creating a new list-based regime known as the Promoting Accountability for Assad and Regional Stabilization Sanctions (“PAARSS”) program. This new framework targets individuals and entities linked to:

• The former Assad regime and their associates;
• Human rights abuses and the forced disappearance of U.S. persons;
• Captagon trafficking and narcotics-related activity;
• Actions that threaten Syria’s stability or obstruct transitional justice.

To prevent bad actors from benefitting from sanctions relief, OFAC simultaneously re-designated 139 individuals and entities under E.O. 13894 and other terrorism- and Iran-related programs. These re-designations excluded major commercial and financial institutions previously removed from the SDN List.

Secondary Sanctions and State Sponsor of Terrorism Designation

E.O. 14312 further directed the U.S. Department of State to evaluate whether to suspend, in whole or in part, the imposition of secondary sanctions under the Caesar Act.[2] With the earlier 180-day waiver, the forthcoming removal of the Syrian Sanctions Regulations (31 C.F.R. Part 542) will effectively terminate the secondary sanctions framework under the Caesar Act.

E.O. 14312 directs the Secretary of State to review Syria’s designation as a State Sponsor of Terrorism (“SST”) and consider lifting it, consistent with evolving U.S. policy. As part of this effort, the State Department revoked the Foreign Terrorist Organization (“FTO”) designation of Hay’at Tahrir al-Sham (HTS) on July 8, 2025. HTS remains designated as a Specially Designated Global Terrorist (SDGT), although that status may also be reconsidered.

Impact on Export Controls

Executive Order 14312 also waives certain export control provisions under the Syria Accountability and Lebanese Sovereignty Restoration Act of 2003 (“SAA”), thereby authorizing the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) to rescind or amend export restrictions imposed under the Export Administration Regulations (“EAR”).[3]

As of this writing, BIS has not yet lifted the Syrian embargo under the EAR, and export controls remain in place. As of now, only EAR99 food and medicine may be exported or reexported to Syria without a license. All other items continue to require BIS authorization.

BIS submitted a final rule for interagency review on June 8, 2025, which is expected to relax restrictions on lower-controlled items and eliminate the presumption of denial for many U.S.-origin items. We will update this article when BIS releases that rule.

Current Status of EU and UK Sanctions Against Syria

As outlined in our previous post, the European Union and the United Kingdom have recently taken steps to ease certain sanctions on Syria. Since those measures were introduced, there have not been any significant new changes from the EU or UK regarding their Syria sanctions frameworks. We continue to closely monitor developments relating to Syria sanctions in both jurisdictions.

Business should exercise caution with remaining restrictions and consult legal counsel to ensure compliance with all applicable sanctions requirements.

Room for Opportunities?

The revocation of the U.S. comprehensive sanctions program marks a watershed moment in Syria’s reintegration into the global economy—but companies should not mistake opportunity for certainty. While the easing of restrictions opens new avenues for engagement, the landscape remains complex and fast-moving.

Hundreds of individuals and entities remain blacklisted under U.S., UK, and EU regimes, and export controls—particularly under the EAR—still apply to the export and reexport of most U.S.-origin goods and technology to Syria.

Businesses looking to re-enter or expand operations in Syria must proceed would be well advised to undertake careful planning, rigorous due diligence, and ongoing compliance oversight. From banking and energy to telecommunications and infrastructure, opportunities are emerging—but so are questions around licensing, counterparties, and shifting legal obligations.

With further guidance expected from BIS and the State Department in the coming weeks, companies should stay agile, engage counsel early, and monitor for developments that could reshape what is permissible—and what remains prohibited—in this evolving sanctions environment.

FOOTNOTES

[1] Available here.

[2] Section 7412 of the Act, codified at 31 C.F.R. § 542.201(a)(13).

[3] 15 C.F.R. § 746.9.