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On June 30, 2025, President Trump issued Executive Order 14312 (the “Executive Order”) terminating several national emergencies related to Syria, 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 and its new government, led by President Ahmed al-Sharaa. The Executive Order also expands an earlier executive order of October 2019, E.O. 13894, to impose additional sanctions on individuals and entities associated with the regime of former Syrian President Bashar al-Assad.

Economic Sanctions Implications

As discussed in our previous blog post, the U.S. government largely suspended sanctions on Syria on May 23, 2025.  Those measures, implemented through an OFAC general license and State Department waiver, were structured to provide temporary sanctions relief such that sanctions could be swiftly reimposed if Syria failed to demonstrate its commitments to “not offer a safe haven for terrorist organizations” and “ensure the security of its religious and ethnic minorities.” 

The Executive Order revokes the national emergencies and executive orders that formed the legal basis of the Syria sanctions program and calls on the relevant agencies to remove President al-Sharaa and the al-Nusrah Front, which he previously led, from the Foreign Terrorist Organizations (“FTOs”) and Specially Designated Global Terrorist lists, as applicable.  OFAC announced in parallel that it will remove the Syrian Sanctions Regulations (31 C.F.R. Part 542, the “SySR”) from the Federal Register.  OFAC also removed individuals and entities blocked solely under the SySR from the SDN List, and stated that all property and interests in property of such individuals and entities will be unblocked.  The State Department similarly announced the termination of sanctions on Syrian entities and individuals pursuant to the Executive Order and, on July 7, 2025, announced the revocation of the designation of the al-Nusrah Front as an FTO. 

The 180-day waiver of secondary sanctions under that Caesar Act previously issued by the State Department remains in effect.  The Executive Order further directs the Secretary of State to determine whether the conditions for suspending sanctions under the Caesar Act have been met and provide a briefing to Congress.  Waivers and suspensions of Caesar Act sanctions are valid for renewable 180-day periods, but permanent revocation of Caesar Act sanctions requires action from Congress, and the Executive Order directs the State Department to continue to “review the situation in Syria,” and to reimpose Caesar Act sanctions if the conditions for suspension of Caesar Act sanctions are no longer being met by the new government.

Under the expanded E.O. 13894, OFAC established a new sanctions program titled “Promoting Accountability for Assad and Regional Stabilization Sanctions (PAARSS).”  On June 30, OFAC added 133 individuals and entities to the SDN List due to their connections to the previous Assad regime.

State Sponsor of Terrorism and Export Controls

The May 23, 2025 suspensions of economic sanctions on Syria had no effect on Syria’s designation as a State Sponsor of Terrorism, nor on export controls restricting exports to Syria of items subject to the U.S. Export Administration Regulations.  The Executive Order now directs the State Department to reconsider Syria’s designation as a State Sponsor of Terrorism and directs the relevant agencies to begin the process of repealing export control restrictions imposed on Syria. 

The relevant statutory authorities for restrictions on exports to Syria – the Syria Accountability and Lebanese Sovereignty Restoration Act of 2003 and the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (the “CBW Act”) – allow for waiver of export control restrictions if certain determinations are made by the President under those authorities.  The Executive Order makes the required determinations and waives the relevant export control restrictions under both statutes, directing the State Department to transmit the waiver under the CBW Act to Congress, after which it will become effective in 20 days. 

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Cleary’s International Trade 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 the Syrian Sanctions Regulations.