In the aftermath of the overthrow of the Assad government on December 8, 2024, the United States has eased (but has not lifted) its longstanding economic sanctions program against Syria. On January 6, 2025, the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") issued Syria General License 24 ("GL24"), titled "Authorizing Transactions with Governing Institutions in Syria and Certain Transactions Related to Energy and Personal Remittances."

In a press release, the Department of the Treasury explained that GL24 is intended "to help ensure that sanctions do not impede essential services and continuity of governance functions across Syria, including the provision of electricity, energy, water, and sanitation."

As amplified by several FAQs, GL24, which remains in effect until July 7, 2025, authorizes U.S. persons to participate in these previously prohibited transactions:

1. Transactions with governing institutions in Syria, even if the particular ministry or its leadership is on OFAC's List of Specially Designated Nationals and Blocked Persons (the "SDN List"), including governing institutions involved with Hay'at Tahrir al Sham, Syria's de facto new ruling group, which remains on the SDN List. The term "governing institution" includes departments, agencies, and government-run public service providers (including public hospitals, schools, and utilities) at the federal, regional, or local level in Syria, across all geographic areas of the country.
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. That is subject, however, to any applicable U.S. Department of Commerce restrictions with respect to U.S.-origin and other goods regulated under the Export Administration Regulations.
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 (which is on the SDN List).

Still prohibited are:

1. The unblocking of property blocked (i.e., frozen) pursuant to existing sanctions regulations.
2. Transactions involving Syrian military or intelligence entities, or persons acting on their behalf.
3. Importation of Syrian petroleum or petroleum products into the United States.
4. 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-origin or Russian-origin goods, technology, software, funds, financing, or services.
5. Financial transfers to any person blocked under Syrian sanctions regulations or terrorist sanctions regulations. GL24 authorizes exceptions where the transfer is for (i) the payment of taxes, fees, or import duties to governing institutions; (ii) the payment of salaries or wages to non-SDN employees of governing institutions; or (iii) the purchase or receipt of permits, licenses, public utility services, or other public services. These exceptions apply even if the particular ministries or their leadership are on the SDN List.
6. New investment in Syria, other than contribution of funds for salaries or wages of non-SDN employees of governing institutions consistent with paragraph (5)(ii) above. 

GL24 does not unblock any property or interests in property that are currently blocked. Syria's designation as a State Sponsor of Terrorism remains in place.

The U.S. Government will surely be monitoring carefully to see if this initial easing of sanctions has a salutary effect on the people of Syria, or if it degenerates into a feeding frenzy for criminal gangs, terrorist organizations, and corrupt officials. In principle, at least until July 7, there are opportunities for U.S. businesses to capitalize on this development. GL24 is complex and laden with land mines. U.S. companies seeking to enter the Syrian market will require experienced sanctions counsel to ensure compliance.