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On May 23, 2025, the U.S. Department of the Treasury, Office of Foreign Assets Control (“OFAC”) issued General License 25 (“GL 25”), titled “Authorizing Transactions Prohibited by the Syrian Sanctions Regulations or Involving Certain Blocked Persons.”  Effective immediately, GL 25 suspends nearly all OFAC sanctions on Syria, in line with President Trump’s prior announcement that he intended to lift sanctions on Syria following the ouster of former Syrian President Bashar al-Assad and the establishment of a new government under Syrian President Ahmed al-Sharaa.

According to an OFAC press release, GL 25 “enable[s] new investment and private sector activity consistent with the President’s America First strategy” and was issued in parallel with the U.S. Department of State’s issuance of a 180-day waiver of Caesar Act secondary sanctions and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network’s provision of sanctions relief to Syria under the USA PATRIOT Act.

GL 25 does not revoke the Syria Sanctions Regulations (“SySR”) (31 C.F.R. Part 542), but rather authorizes most transactions otherwise prohibited by the SySR.  In a subsequent fact sheet published May 28, 2025, OFAC elaborates that GL 25 authorizes, among other transactions: “the provision of services to people and companies in Syria; new investment in Syria; the import of or dealing in petroleum and petroleum products from Syria; transactions with the new Government of Syria; [and] transactions involving certain blocked persons, which are listed in the Annex to GL 25,” which includes 28 entities and persons, including, among others, Syrian Arab Airlines, the Commercial Bank of Syria, the Central Bank of Syria, General Petroleum Corporation, the Syrian Company for Oil Transport, the Syrian Petroleum Company, and the Syrian Gas Company.  The fact sheet states that continued sanctions relief for Syria depends on the new Syrian government’s demonstration of its commitments to “not offer a safe haven for terrorist organizations” and “ensure the security of its religious and ethnic minorities.”

In addition to broadly authorizing transactions otherwise prohibited by the SySR, GL 25 also authorizes transactions otherwise prohibited by the Weapons of Mass Destruction Proliferators Sanctions Regulations (31 C.F.R. Part 544), the Iranian Financial Sanctions Regulations (31 C.F.R. Part 561), the Global Terrorism Sanctions Regulations (31 C.F.R. Part 594), the Foreign Terrorist Organizations Sanctions Regulations (31 C.F.R. Part 597), and Executive Order 13574 if such transactions involve the current Government of Syria (led by President al-Sharaa), any blocked person listed in the GL 25 Annex, and any entity 50% or more owned by one or more persons listed in the GL 25 Annex.  The fact sheet states that examples of authorized transactions include telecommunication-related services and financial and investment services.  U.S. banks are now authorized to process transactions for any activities authorized under GL 25.

GL 25’s authorizations are subject to the following exceptions: GL 25 does not (1) authorize transactions with Specially Designated Nationals and Blocked Persons (“SDNs”) not expressly listed in the GL 25 Annex, (2) unblock any property or interests in property blocked under the SySR as of May 22, 2025, or (3) authorize any transactions related to Russia, Iran, or North Korea, or for or behalf of the governments of those countries. 

Furthermore, GL 25 has no effect on U.S. export controls; all items subject to the Export Administration Regulations still require a license for export to Syria, with limited exceptions for certain food and medicine.  Likewise, Syria remains listed as a State Sponsor of Terrorism, which separately imposes certain additional restrictions on payments and exports.   

EU and UK Sanctions on Syria

Although Syria was not subject to EU or UK territory-wide sanctions as comprehensive in scope as those imposed by the United States, the European Union and United Kingdom have also taken actions to scale back sanctions on Syria since the ouster of the Assad regime.  In February 2025, the EU suspended certain sectoral sanctions on Syria, unblocked certain Syrian entities, and eased financial sanctions on Syrian banks and financial institutions, among other measures.  In March and April 2025, the UK similarly lifted certain sectoral sanctions and unblocked certain Syrian entities.  On May 20, 2025, the EU announced its intent to further lift economic sanctions on Syria, and on May 28, 2025, the EU formally adopted legal acts lifting the remaining economic restrictive measures on Syria, although stringent export restrictions remain in place for security purposes.  Individuals and entities with ties to the former Assad regime also remain subject to sanctions.