Gradual Lifting of the Syria Sanctions

Following President Trump’s announcement during his Gulf tour, the United States formally took the first step toward a comprehensive relaxation of the U.S. Syria sanctions. Specifically, OFAC issued General License 25 (“GL 25”) on May 23, 2025, which now authorizes:

- The provision of services to Syria

- New investment in Syria

- The import of / dealing in petroleum and petroleum products from Syria

- Transactions with the new Government of Syria

- Transactions involving certain sanctioned persons listed in the Annex of GL 25

Per the OFAC guidance issued on May 28, 2025, authorized transactions under GL 25 include – but are not limited to – services relating to:

- Telecommunications

- Power grid infrastructure rehabilitation and other energy

- Health care

- Education

- Agriculture

- Civil-aviation and other transportation

- Construction

- Water and waste management

- Finance and investment

The above constitutes a non-exhaustive list. Where unsure if a contemplated Syria transaction falls within the scope of authorizations, it is advisable to seek sanctions counsel to guard against a potential violation.

Barring a policy change from the Trump Administration, GL 25 is set to remain in force indefinitely for U.S. persons.  In contrast, the authorizations for non-U.S. persons (against secondary sanctions risk) are currently valid for 180-days, given the legislative component of the U.S. Syria sanctions program (Caesar Act) which requires that the State Department submit a waiver to Congress.

As broad as the scope of relaxations are, it is important to note several restrictions remain in place.  Namely, transactions involving SDNs / blocked persons that are not explicitly authorized by GL 25 can still create sanctions exposure.  Moreover, Syrian transactions with a nexus to Iran, Russia, and North Korea are carved out from the authorizations of the GL (i.e. are prohibited).  Finally, as export controls operate distinctly from sanctions, the export of most U.S.-origin items to Syria still require a license from the U.S. government – without which there may separately be an export controls violation.

Other major jurisdictions like the EU and the UK have likewise lifted most of their sanctions against Syria.  However, as with the U.S., there are still residual restrictions that remain.  Thus, we recommend businesses contemplating Syria transactions to carefully study, and consult where necessary, what is now allowed and what still remains prohibited.