Trump Administration Issues Broad Sanctions Relief for Syria, Effectively Lifting 14 Years of Comprehensive Economic Sanctions – U.S. Export Controls Remain in Place for Now as Europe Forges Ahead and Removes Most Syria Trade Controls

On May 23, 2025, 10 days after President Trump announced his directive to lift U.S. sanctions on Syria during his visit to Saudia Arabia last month, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria-related General License 25 (GL 25), which provides broad sanctions relief by authorizing, subject to certain exceptions: (i) all transactions prohibited by OFAC’s Syrian Sanctions Regulations aside from those involving certain sanctioned persons, and (ii) all transactions prohibited by OFAC’s Syrian Sanctions Regulations and certain other enumerated OFAC sanctions programs involving the Government of Syria and 28 sanctioned persons listed in the annex of GL 25 (as well as their majority-owned entities). 

OFAC guidance published within days of GL 25’s issuance clarifies that GL 25 generally authorizes:

• The provision of services to individuals and entities in Syria;
• New investment in Syria;
• Imports of, and dealings in, Syrian petroleum and petroleum products;
• Transactions with the new Government of Syria (but not with the former Syrian regime); and
• Dealings with the sanctioned persons listed in GL 25’s annex.

GL 25 represents a dramatic (albeit not surprising) move that upends the U.S. Syria sanctions landscape – and a significant part of the United States’ longstanding foreign policy in the Middle East – roughly six months after Syrian dictator Bashar al-Assad was ousted from power last December. It accords with similar actions taken in the European Union (EU) and United Kingdom (UK), among other jurisdictions where certain sanctions have been lifted. As of now, the U.S. Commerce Department’s Bureau of Industry and Security (BIS) has not taken corresponding easing measures, meaning that U.S. export controls with respect to Syria remain in place. The EU and UK, on the other hand, lifted most of their trade restrictions against Syria. 

The OFAC action is one of several steps that the Trump Administration has taken to ease restrictions on Syria and bolster its war-torn economy. The U.S. Treasury press release accompanying GL 25’s issuance describes GL 25 as “just one part of a broader U.S. government effort to remove the full architecture of sanctions imposed on Syria due to the abuses of the Bashar al-Assad regime” and cites the U.S. Department of State’s concurrent secondary sanctions-related waiver under the Caesar Syria Civilian Protection Act of 2019, as well as the Financial Crimes Enforcement Network’s exceptive relief to permit U.S. financial institutions to maintain correspondent accounts for the Commercial Bank of Syria. 

I. GL 25 Authorized Transactions

GL 25 broadly authorizes, subject to certain exceptions:

1. All transactions prohibited by OFAC’s Syrian Sanctions Regulations apart from those involving most individuals and entities designated and identified on OFAC’s Specially Designated Nationals and Blocked Persons List (“SDN List”), as well as any entities owned, directly or indirectly, 50 percent or more in the aggregate by one or more such designated persons (collectively, “blocked persons”); and
2. All transactions prohibited by OFAC’s Syrian Sanctions Regulations, as well as certain other enumerated OFAC sanctions (e.g., OFAC’s global terrorism sanctions), involving the Government of Syria “as in existence on or after May 13, 2025” (including Syrian President Ahmed al-Sharaa and his government) and the 28 blocked persons listed in the annex to GL 25 and their majority-owned entities.

As previewed above, OFAC issued a fact sheet with additional guidance clarifying examples of the types of services now broadly authorized, including those related to telecommunications, power grid infrastructure rehabilitation, energy, healthcare, education, agriculture, civil aviation, transportation, construction, water and waste management, and financial investment. 

To provide assurances to U.S. financial institutions and other U.S. persons, the guidance explicitly provides that “U.S. banks are authorized to process transactions for any activities authorized by GL 25[,]” and U.S. persons “are authorized to provide support to the new Government of Syria.” OFAC emphasizes this point in particular as it relates to humanitarian activities in Frequently Asked Question (FAQ) 8 on the fact sheet, stating that U.S. depository institutions, U.S. registered brokers and dealers in securities, and U.S. registered money transmitters may rely on statements from nongovernmental organizations engaged in authorized activities in order to process transactions. 

As most of our readers are already aware, general licenses are regulatory documents that OFAC issues to authorize a particular type of transaction for a category of persons without the need to submit a written application to OFAC. Thus, so long as a transaction falls within GL 25’s scope and does not trigger any of the exceptions described below, the parties to the transaction may avail themselves of GL 25’s authorizations without any outreach to OFAC.

 II. GL 25 Exceptions

Notwithstanding the far-reaching authorizations described above, GL 25 does not authorize:

1. Any transactions involving blocked persons not listed in GL 25’s annex, such as, e.g., former Syrian dictator Bashar al-Assad;
2. The unblocking of any property or interests in property blocked (i.e., frozen) pursuant to any of OFAC’s regulations (31 C.F.R. Chapter V) as of May 22, 2025; or
3. Any transactions for or on behalf of the Russian, Iranian, or North Korean governments – which Treasury characterized in its press release as “key supporters of the former Assad regime” – or in connection with the transfer or provision of “goods, technology, software, funds, financing, or services to or from Iran, Russia, or [North Korea].”

As is the case with all OFAC general license analyses – whether GL 25 authorizes a particular transaction or set of transactions will be a fact-driven inquiry that will hinge particularly here on whether any blocked persons are involved, and if so, whether those blocked persons (or their majority-owned entities) are listed in GL 25’s annex.  

 III. The EU and UK Forge Ahead

In the meantime, the EU and UK have gone one step further by lifting (rather than merely suspending) most financial and trade sanctions against Syria, including certain export restrictions.

Following the EU’s suspension of several restrictive measures under its Syria sanctions regime on February 24, 2025, the EU lifted most of its remaining sanctions against Syria on May 27, 2025. Like U.S. sanctions, EU “blocking sanctions” remain in place against certain designated individuals and entities linked to Bashar al-Assad’s former regime. Trade sanctions remain in effect for particularly security-sensitive goods, technology, and software, including arms and military goods, dual-use items, and equipment for internal repression and monitoring. EU trade sanctions still prevent dealings in Syrian cultural property goods where the goods may have been removed from Syria without the consent of their legitimate owner or in breach of Syrian or international law.

Similarly, the UK lifted some of its sanctions on Syria on March 6, 2025, and again on April 24, 2025. Asset freezes have been lifted on some entities, including the Central Bank of Syria, the Commercial Bank of Syria, the Syrian Ministry of Defense, the Ministry of the Interior, and several media organizations, but they still apply to Bashar al-Assad’s former regime. Restrictions on certain sectors of the Syrian economy – including the energy, transport, insurance, and banking sectors – have also been lifted. Certain trade sanctions have been lifted, but those relating to certain precious metals, diamonds, luxury goods, military goods and technology, goods and technology related to chemical and biological weapons, and internal repression, interception, and monitoring items remain in place. The UK also updated its statutory guidance on Syria sanctions.

 IV. Top Five Takeaways

Below are our top five takeaways from GL 25 and the lifting of certain EU and UK sanctions against Syria:

1. Typical Comprehensive Sanctions Prohibitions Eased. Syria is one of a handful of countries/territories previously targeted by U.S. comprehensive sanctions (along with Cuba, Iran, North Korea, and the Crimea, Donetsk, and Luhansk regions of Ukraine), which prohibit most dealings involving such countries/territories subject to U.S. jurisdiction. As GL 25 authorizes most dealings prohibited by the Syrian Sanctions Regulations (where most of the typical comprehensive sanctions prohibitions for Syria are found), OFAC’s Syria sanctions program now only prohibits dealings with certain blocked persons, which effectively makes it more akin to OFAC’s numerous other “list-based” sanctions programs.
2. There Are Still Many Blocked Persons in Syria to Avoid. Those intent on engaging in transactions authorized by GL 25 must take care not to inadvertently engage in any dealings involving blocked persons not included in the annex to GL 25 (or their majority-owned entities). As of the date of this alert, there remain nearly 700 blocked individuals and entities in Syria – not including those persons blocked as a result of their sanctioned majority ownership – which makes strong internal controls such as screening and due diligence all the more critical when contemplating dealings potentially authorized by GL 25. Similarly, a significant number of individuals, entities, and organizations in Syria remain designated under the EU and UK sanctions regimes.
3. Risk of Revocation. OFAC issues and may revoke general licenses quickly and without warning in line with U.S. national security and foreign policy changes. Thus, GL 25 is not guaranteed to be permanent. The fact sheet of nine FAQs on GL 25 that OFAC issued on May 28, 2025, hints that the U.S. government may revoke GL 25 if the new Syrian government backslides on its commitments, stating “U.S. sanctions relief has been extended to the new Syrian government with the understanding that the country will not offer a safe haven for terrorist organizations and will ensure the security of its religious and ethnic minorities. The U.S. will continue monitoring Syria’s progress and developments on the ground.” Because U.S. sanctions are strict liability, a revoked general license means dealings authorized by the revoked general license become automatically prohibited again, exposing parties engaged in applicable transactions to immediate civil liability. It is therefore imperative for companies to take stock of their risk appetite and ensure their sanctions compliance controls are commensurate with that risk appetite and, where applicable, able to adapt promptly to a possible revocation of GL 25. (Notwithstanding these considerations, we note the lifting of sanctions on Syria has received bipartisan support, and commencing sanctions relief with a general license is consistent with the approach the U.S. government took to lift sanctions on Sudan and other countries.) By contrast, the EU and UK have lifted most of their Syria-related sanctions and would have to re-adopt the removed measures through the applicable formal procedure.
4. Sanctions Easing Represents an Authorization, Not a Requirement, to Engage With Syria. Just because the United States, EU, and UK are allowing their citizens and companies to engage in Syria does not mean that financial institutions and other global entities will want to take the sanctions compliance and other business risks to enter the country. Companies that want to begin or expand their footprint in or involving Syria may find their banks and other service providers unwilling to participate.
5. Secondary Sanctions Risks Minimized for Now. OFAC’s Syria sanctions program includes secondary sanctions, which are legal authorities that allow for sanctions to be imposed on non-U.S. persons engaged in proscribed conduct outside U.S. jurisdiction. These secondary sanctions authorities include Section 7412 of the Caesar Syria Civilian Protection Act of 2019 (Caesar Syria Act) and Section 234 of the Countering America’s Adversaries Through Sanctions Act of 2017 (CAATSA). With respect to the Caesar Syria Act, the U.S. Department of State waived the imposition of secondary sanctions on non-U.S. persons engaged in conduct authorized by GL 25 for 180 days (i.e., until November 19, 2025). Although no formal actions have yet been taken to ease the secondary sanctions noted in Section 234 of CAATSA, which target non-U.S. persons who provide significant support for certain nefarious activities conducted by the Government of Syria, FAQ 5 in the May 28, 2025, OFAC fact sheet clarifies that “[n]on-U.S. persons would not risk exposure under U.S. sanctions for facilitating transactions or payments for such activities that would be authorized for U.S. persons pursuant to GL 25.” Accordingly, the secondary sanctions risks to non-U.S. persons engaged in conduct authorized by GL 25 have disappeared, assuming compliance with the terms of the sanctions that remain.

V. Conclusion

In conclusion, the issuance of GL 25 and corresponding actions in the EU and UK mark watershed shifts in Western national security and foreign policy that open Syria to a wide range of business activities and economic investments. However, OFAC clearly states on its fact sheet that it “will continue to enforce sanctions on Assad and his enablers, serious human rights abusers, Captagon drug traffickers, and persons involved in terrorist and proliferation activity,” and the EU recently adopted new restrictive measures targeting two Syrian individuals and three Syrian entities for serious human rights abuses under the EU Global Human Rights Sanctions Regime. Companies looking to engage in Syria-related transactions must therefore continue to (i) invest in screening and due diligence to ensure prospective activity complies with existing authorizations, including GL 25, and any remaining sanctions and export controls, and (ii) monitor any relevant changes (e.g., newly offered guidance from OFAC or BIS, waiver expirations, general license revocations, or any further changes to the EU and UK Syria sanctions programs and related guidance by the UK government, the European Commission, or competent national sanctions authorities in the EU) that could alter the scope of authorized activity. While the issuance of GL 25 and the lifting of EU and UK sanctions against Syria are significant milestones, a conclusive end to the U.S. embargo and the remaining EU and UK sanctions on Syria will likely be a step-by-step endeavor, and the landscape of permitted transactions could shift before that end is reached.  

In the meantime, the MoFo National Security team is available to guide companies, financial institutions, non-profit organizations, and more through these Syria sanctions developments, including how they relate to bolstering sanctions compliance policies and procedures to withstand any major changes in the future.

Paralegal Annie Lubin contributed to this alert.