On May 23, 2025, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License 25 (GL 25), titled “Authorizing Transactions Prohibited by the Syrian Sanctions Regulations or Involving Certain Blocked Persons.” GL 25 effectively suspends OFAC sanctions targeting Syria. This comes 10 days after President Trump announced during an appearance at the Gulf Cooperation Council summit in Riyadh, Saudi Arabia, that he was “ordering the cessation of sanctions against Syria to give them a fresh start.” Calling the sanctions “really crippling” and “very powerful,” President Trump stated that easing sanctions against Syria would give the country “a chance for greatness.”
Treasury explained in a press release accompanying the general license that GL 25 “is intended to help rebuild Syria’s economy, financial sector, and infrastructure, in line with US foreign policy interests.” Treasury indicated that the sanctions relief is contingent on the new Syrian government safeguarding its religious and ethnic minorities and not offering safe harbor to terrorist groups. The US government will monitor Syria’s progress toward these goals. As stated in the press release, the sanctions relief is part of a broader strategy aimed at dismantling the US government’s Syrian sanctions framework established many years ago in response to the abuses perpetrated by the former Bashar al-Assad regime.
In parallel, the US Department of State issued a 180-day waiver of mandatory “Caesar Act” sanctions to facilitate investment in key sectors of the Syrian economy. The Financial Crimes Enforcement Network (FinCEN) also provided relief under the USA Patriot Act, allowing US financial institutions to open and maintain correspondent accounts for the Commercial Bank of Syria (subject to certain restrictions identified in FinCEN’s notice).
Notably, GL 25 does not revoke OFAC sanctions targeting Syria, but rather provides authorization to engage in transactions prohibited by the Syrian Sanctions Regulations (31 CFR Part 542). This includes activities such as: exporting financial and other services to Syria; making a “new investment” in Syria; and engaging in transactions related to Syria-origin petroleum or petroleum products.
This approach is similar to actions taken by the Obama administration in January 2017, when OFAC issued a new general license authorizing most trade and business involving US persons and Sudan — including by authorizing all prohibitions that were in the Sudanese Sanctions Regulations (for more details, see our Client Alert). The US government made termination of economic sanctions against Sudan contingent on Sudan making progress with respect to certain key areas related to reducing conflict, increasing humanitarian access to the country, and fighting terrorism. While Sudan worked to demonstrate progress in these key areas, the United States maintained flexibility with respect to its approach to Sudan, since general licenses can be revoked at any time without warning. The United States eventually removed economic sanctions against Sudan by revoking the Sudanese Sanctions Regulations effective October 12, 2017.
GL 25 also authorizes transactions with the current government of Syria under President Ahmed al-Sharaa and permits transactions with the Specially Designated Nationals and Blocked Persons (SDNs) listed in the GL 25 Annex, which include the Central Bank of Syria, the Commercial Bank of Syria, and Syrian Arab Airlines.
Notably, the Syrian government, including President al-Sharaa, reportedly has ties to Hay’at Tahrir al-Sham (HTS), which is an entity on the State Department’s list of Foreign Terrorist Organizations (FTOs). Despite GL 25’s authorization to engage with the Syrian government, the so-called “Material Support Statute” at 18 USC § 2339B continues to provide independent criminal liability for a person who “knowingly provides material support or resources to a foreign terrorist organization, or attempts or conspires to do so,” which includes HTS.
Except for the 28 parties identified in the GL 25 Annex, GL 25 does not authorize transactions and dealings with Syria-related parties on the SDN List (or entities 50% or more owned by one or more such parties). There continue to be many hundreds of persons on the SDN List in Syria, including large corporations (such as Syriatel, a mobile network provider). As a result, Syria can continue to pose sanctions risks due to the high concentration of SDNs in Syria, which US persons generally cannot transact with, absent OFAC authorization.
GL 25 also does not authorize the unblocking of property or interests in property that were blocked as of May 22, 2025.
Finally, Treasury made clear in its press release that GL 25 “does not allow for transactions that benefit Russia, Iran, or North Korea — key supporters of the former Assad regime.” For instance, GL 25 does not authorize transactions for or on behalf of the Russian, Iranian, or North Korean governments (that are otherwise prohibited by the Syrian Sanctions Regulations). As an example, GL 25 would not authorize a US person to facilitate a “new investment” in Syria by one of these governments. Similarly, GL 25 does not authorize the transfer or provision of goods, technology, software, funds, financing, or services to or from Iran, Russia, or North Korea.
GL 25 does not impact the long-standing export control prohibition on exports or reexports of US-regulated items to Syria. Almost all items (including commodities, software, or technology) that are subject to the Export Administration Regulations (EAR) require licensing to be exported or reexported to Syria, even on a temporary basis (with the exception of a narrow permission for news media found at Section 740.9(a)(9) of the EAR). This includes very basic items (i.e., so-called EAR99 items) as well as EAR-regulated laptops, tablets, cell phones, satellite phones, and other common tools of the trade. Currently, US export licensing is not required for exports or reexports to Syria of food items and EAR99 medicines.
Unless and until the US Department of Commerce takes steps to ease these export control restrictions, Syria will remain virtually off-limits as a destination for US-regulated items. We are monitoring the EAR for changes that would ease these stringent US export controls. We also expect that the Commerce Department’s Bureau of Industry and Security (BIS) will announce relevant changes on its website at https://www.bis.gov.
Several officials in the EU and its Member States have argued for significantly reducing sanctions against Syria. However, to date, the EU’s actions have been relatively limited. On February 24, 2025, the EU suspended sanctions relating to the energy and transport sectors. It also removed asset freezes on four major Syrian banks and one airline. In addition, it permitted funds and resources to be made available to the Syrian Central Bank and extended exemptions relating to humanitarian situations and the personal use of luxury goods. On May 20, 2025, the EU announced a “political decision” to lift further sanctions. However, the EU has not yet amended measures to reflect this announcement.
The UK’s amendments to its Syria-related sanctions to date are similar to those by the EU. On March 6, 2025, the UK removed asset-freeze sanctions on Syrian banks, energy entities, and transport entities. The UK subsequently dropped sanctions on several Syrian government entities and prohibitions relating to fuel/energy and the Central Bank of Syria. Further amendments are under consideration.
It remains to be seen whether the US actions of May 23, 2025, will influence the EU’s or the UK’s processes of lifting further sanctions.