President Trump continued his flurry of sanctions actions with the recent revocation of the Syrian sanctions program. On June 30, 2025, President Donald Trump issued Executive Order (“EO”) 14312 “Providing for the Revocation of Syria Sanctions” marking a significant shift in U.S. sanctions policy toward Syria. Effective July 1, 2025, this E.O. terminated the comprehensive sanctions program previously imposed on Syria, reflecting the U.S. government’s recognition of positive developments under the new Syrian government led by President Ahmed al-Sharaa. This development opens new opportunities for investment and business in Syria but requires careful navigation of remaining sanctions, compliance obligations, and evolving regulatory frameworks.
Background and Policy Shift Regarding Syria
The U.S. sanctions program on Syria was initially designed to address human rights abuses, support for terrorism, and regional destabilization under the policies of Bashar al-Assad. However, circumstances have changed over the past several months, driven by the new Syrian government’s actions under President Ahmed al-Sharaa. As such, EO 14312 seeks to provide the new Syrian government with an opportunity to become “stable, unified, and at peace with itself and its neighbors.” This policy shift aligns with broader U.S. national security and foreign policy goals, including fostering economic recovery in Syria and countering terrorism without empowering human rights abusers, terrorist organizations, or those linked to chemical weapons or proliferation activities. The U.S. aims to support a stable, unified, and peaceful Syria while maintaining accountability for malign actors.
Executive Orders Revoked
Effective July 1, 2025, E.O. 14312 terminates the national emergency declared in EO 13338 of May 11, 2004 and revokes the following six EOs that formed the foundation of the Syria sanctions program:
- E.O. 13338 (2004): Blocked property of certain persons and prohibited exports of specific goods to Syria.
- E.O. 13399 (2006): Expanded blocking of additional persons connected to the Syria emergency.
- E.O. 13460 (2008): Further expanded property blocking for additional persons.
- E.O. 13572 (2011): Targeted persons responsible for human rights abuses in Syria.
- E.O. 13573 (2011): Blocked property of senior Syrian government officials.
- E.O. 13582 (2011): Blocked property of the Government of Syria and prohibited certain transactions, including investments and petroleum-related activities.
As a result, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has removed the Syrian Sanctions Regulations—31 CFR Part 542—from the Code of Federal Regulations. This eliminates much of the comprehensive economic sanctions that previously prohibited U.S. persons from engaging in most transactions with Syria, including investments, financial services, and trade in goods and services.
Changes to the SDN List Following Syrian Sanctions Revocation
The revocation of the Syria sanctions program led to sweeping updates to OFAC’s SDN List:
- Removal of 518 Individuals and Entities: OFAC removed 518 individuals and entities previously designated solely under the Syria sanctions program. This includes key entities critical to Syria’s development, such as the Central Bank of Syria, Syrian Arab Airlines, and state-owned enterprises.
- Redesignation Under PAARSS Program: Certain individuals and entities, including Bashar al-Assad and his associates, remain sanctioned under the newly established Promoting Accountability for Assad and Regional Stabilization Sanctions (“PAARSS”) program, which expands the national emergency declared in EO 13894 (2019). OFAC redesignated several key individuals operating in this country under E.O. 13894, ensuring continued accountability for human rights abuses, narcotics trafficking, and other destabilizing activities.
- Continued Sanctions on Other Actors: Sanctions remain in place for individuals and entities linked to terrorism (e.g., ISIS, Al-Qa’ida affiliates), human rights abuses, captagon trafficking, chemical weapons activities, and Iran or its proxies. Many of these entities operate within Syria. These sanctions are administered under separate authorities and other regional sanctions programs—which means these sanctions are still active.
Additional Actions and Waivers
In addition to the changes in the SDN List, EO 14312 introduces several measures to facilitate Syria’s reintegration into global commerce:
- Caesar Act Waiver and Potential Suspension: The State Department issued a 180-day waiver of mandatory sanctions under the Caesar Syria Civilian Protection Act of 2019 on May 23, 2025, which remains in effect. EO 14312 directs the Secretary of State to evaluate whether conditions for suspending Caesar Act sanctions are met, subject to renewable 180-day periods. This suspension provides a temporary window for transactions; however, doing so will require ongoing monitoring for potential reimposition.
- Export Control Relaxation: The EO waives certain export controls mandated by the Syria Accountability and Lebanese Sovereignty Restoration Act of 2003 and the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991. However, the Department of Commerce retains jurisdiction over exports to Syria, and companies must still verify compliance with the Export Administration Regulations (“EAR”).
- General License 25 (GL 25): Initially issued on May 23, 2025, GL 25 authorizes transactions previously prohibited by the Syrian Sanctions Regulations, including those involving the interim Syrian government, its central bank, and state-owned enterprises. GL 25 remains in effect for transactions prohibited by other sanctions programs (e.g., terrorism-related designations) and supports new investment and private sector activity.
- Financial Services: U.S. financial institutions are no longer prohibited from providing services to Syria, processing payments involving Syrian financial institutions, or establishing correspondent banking relationships, provided no SDN-listed parties are involved. The Financial Crimes Enforcement Network (“FinCEN”) issued exceptive relief in May 2025 to permit U.S. banks to maintain correspondent accounts for the Commercial Bank of Syria.
Compliance Considerations for Syria
While the revocation of Syria sanctions presents significant opportunities, the country still presents a relatively high risk from a compliance perspective. As such, companies must adopt a robust compliance approach to mitigate risks remaining risks:
- Screening for Remaining SDNs: Companies must continue screening all parties to transactions against the SDN List, as individuals and entities redesignated under the PAARSS program or other authorities (e.g., EO 13894, EO 13224) remain blocked. This includes, for example, Bashar al-Assad, his associates, and terrorism-related actors.
- Due Diligence on Syrian Entities: Although many Syrian entities are no longer sanctioned, companies should conduct enhanced due diligence to confirm ownership structures and ensure no indirect dealings with SDNs. The unblocking of entities owned 50% or more by previously designated persons requires careful verification.
- Export Compliance: Despite waivers, certain export controls under the EAR may stioll apply. Companies should identify any applicable licensing requirements, particularly for dual-use items or technology.
- Caesar Act Monitoring: The 180-day waiver and potential suspension of Caesar Act sanctions are temporary for the time being. Companies should monitor State Department announcements for renewal or reimposition risks.
- Pending Investigations: OFAC will still pursue investigations or enforcement actions for violations of the Syrian Sanctions Regulations that occurred before July 1, 2025. Companies should review past transactions for potential exposure and maintain records for at least five years.
- Terrorism Designations Review: EO 14312 directs the Secretary of State to review the Foreign Terrorist Organization and Specially Designated Global Terrorist designations of Hay’at Tahrir al-Sham and President Ahmed al-Sharaa, as well as Syria’s State Sponsor of Terrorism designation. Changes to these designations could further ease restrictions but are not guaranteed. Companies should avoid transactions with with these individuals until their status is clarified.
- Risk-Based Compliance Programs: OFAC encourages financial institutions and companies to update sanctions compliance programs to reflect new business lines in Syria. This includes training, risk assessments, and robust screening processes to address evolving risks, such as drug trafficking or Iranian influence.
- UN Sanctions: The Secretary of State is directed to explore sanctions relief at the United Nations, which could align international frameworks with U.S. policy. Companies should monitor UN developments for additional opportunities or compliance obligations.
Strategic Opportunities Pursuant to the Revocation of Syrian Sanctions
The revocation of Syria sanctions unlocks significant potential for Fortune 500 companies in sectors such as energy, infrastructure, finance, and humanitarian aid. Key opportunities include:
- Investment and Reconstruction: GL 25 and the Caesar Act waiver facilitate investments in electricity, water, sanitation, and other critical infrastructure, aligning with Syria’s reconstruction needs.
- Financial Sector Engagement: U.S. financial institutions can establish correspondent banking relationships and process payments, supporting trade and investment.
- Trade in Goods and Services: The removal of prohibitions on exports and services enables companies to engage in commerce with Syrian entities, subject to EAR compliance.
- Humanitarian and Stabilization Efforts: Eased restrictions enhance the ability of NGOs and companies to support humanitarian assistance and stabilization projects, fostering goodwill and market access.
Conclusion
The revocation of Syria sanctions under EO 14312 represents an opportunity for companies to engage with Syria’s economy. However, doing so is not without risks and will require a very careful approach. The continued designation of certain individuals and entities under the PAARSS program, temporary waivers, and potential enforcement actions necessitate a cautious and compliant approach. Companies should leverage robust sanctions compliance programs, conduct thorough due diligence, and stay informed of regulatory developments to capitalize on these opportunities while mitigating risks. Furthermore, compliance risks outside of the trade compliance realm still exist, such as bribery and corruption risks.