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On July 8, 2026, President Trump informed Congress of his administration’s intent to rescind Syria’s designation as a State Sponsor of Terrorism (SST), giving Congress the requisite 45-day pre-notification period. The rescission of Syria’s SST designation is one of the final steps in the rollback of financial and other trade restrictions against Syria following President Trump’s June 30, 2025 Executive Order revoking executive orders that imposed sanctions and export restrictions on Syria, and directing the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), U.S. Department of State, and U.S. Department of Commerce to ease trade and finance restrictions on Syria. Syria’s designation as an SST is set to expire following a 45-day mandatory congressional review period, absent formal opposition from Congress.
I. SST Designation of Syria Set to End After Almost 50 Years
The U.S. designated Syria as an SST in 1979 under the Export Administration Act of 1979 (EAA) on the basis that Syria was engaged in international terrorism.[1] An SST designation imposes stringent export license requirements for dual-use goods, prohibits arms exports, prohibits U.S. foreign aid, and limits foreign tax credits for income taxes paid to SST-designated countries.[2] The SST designation automatically invokes additional export control processes for goods listed on the U.S. Export Administration Regulations (EAR), with a general policy of denial for most license applications and ineligibility for most license exceptions.[3] SST designations also require the U.S. government to oppose designated countries’ membership in international financial institutions and eliminates designated countries’ sovereign immunity in U.S. courts.[4]
As discussed in our previous blog post, the U.S. government terminated comprehensive territory-wide sanctions on Syria in June 2025 through Executive Order 14312. E.O. 14312 also directed the U.S. Department of State to reconsider Syria’s designation as a State Sponsor of Terrorism. On September 2, 2025, the U.S. Department of Commerce, Bureau of Industry and Security relaxed export controls on Syria, including through issuing License Exception Syria Peace and Prosperity (SPP), which generally authorizes most exports of items designated EAR99 to Syria.[5] The 2026 National Defense Authorization Act, signed into law in December 2025, repealed the Caesar Syria Civilian Protection Act of 2019, which rolled back remaining threats of U.S. secondary sanctions on parties engaged in dealings with Syria.[6]
II. Effect of Removal
Rescinding the SST designation of Syria brings notable legal, financial, and reputational benefits. Most significantly, the removal of Syria from the SST list will enable the U.S. Department of Commerce to further ease export controls on Syria and may improve access to international financial system, including the resumption of eligibility for U.S. foreign aid. In addition, following the delisting, U.S. victims of Syrian terrorism will have a six-month window in which to file claims for damages arising from acts that occurred during the period in which Syria held the SST designation, pursuant to the Terrorism Exception to the Foreign Sovereign Immunities Act.[7]
III. Remaining Restrictions on Syria
Notwithstanding the delisting of Syria as an SST, many items subject to the EAR and classified under an ECCN other than EAR99 (which are generally authorized under License Exception SPP, as discussed above) will continue to require a license from OFAC for export to Syria pending further action from the U.S. Department of Commerce. The EU and UK have likewise rolled back the most stringent sanctions on Syria, maintaining, like the United States, limited sanctions related to individuals from the Assad regime, arms embargoes, and restrictions on the export of dual-use goods to Syria.
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Cleary’s Foreign Investment and National Security team is continuing to track developments on the Trump administration’s sanctions policy, and is available to provide guidance on navigating the impact of the revocation of economic sanctions and export controls against Syria.
Summer Associates Elizabeth Kean, Ana Paula Sanchez, Dylan Schneider, and Summia Tora also contributed to this article.
[1] The EAA was repealed and replaced by the Export Control Act of 2018, under which Syria’s designation as an SST has remained in place.
[2] See U.S. Department of State, “State Sponsors of Terrorism,” available at https://www.state.gov/state-sponsors-of-terrorism; 26 U.S.C § 901(j)(2)(iv); Section 40 of the Arms Export Control Act (AECA; P.L. 90-629; 22 U.S.C. 2780); Section 620A of the Foreign Assistance Act of 1961 (FAA’61; P.L. 87-195; 22 U.S.C. 2371); and Section1754(c) of the Export Controls Act of 2018 (ECA’18; part I, subtitle B, title XVII, of the John S. McCain National Defense Authorization Act for Fiscal Year 2019; P.L. 115-232; 50 U.S.C. 4813).
[3] See 15 C.F.R. § 746.9.
[4] Section 102 of the Arms Export Control Act (AECA; P.L. 90-629; 22 U.S.C. 2780); Section 1605A of Title 28 of the U.S. Code (Terrorism Exception to the Jurisdictional Immunity of a Foreign State).
Year 2019; P.L. 115-232; 50 U.S.C. 4813); Section 1605A of Title 28 of the U.S. Code (Terrorism Exception to the Jurisdictional Immunity of a Foreign State; 28 U.S.C. 1605A).
[5] See 2025-16724 (90 FR 42315); see also 15 C.F.R. § 740.5.
[6] We discussed the repeal of the Caesar Act in a previous blog post, https://www.clearygottlieb.com/news-and-insights/publication-listing/trade-controls-foreign-investment-and-national-security-new-regimes-and-continuing-changes-for-2026.
[7] See 28 U.S.C. 1605A(a)(2)).