Pursuant to a sweeping new executive order (EO) issued on June 30, 2025, the Trump administration has lifted virtually all U.S. sanctions targeting Syria, shuttered the Syria sanctions program administered by the Office of Foreign Assets Control (OFAC), and directed the review or removal of other restrictions on dealings with Syria and the government of Syria. This action follows closely on the heels of general license (GL) 25 and certain other actions taken by OFAC and the State Department to relax — but not entirely rescind — the suite of restrictions with respect to Syria, as discussed in our June 3, 2025, alert (the June 3 Alert).
President Donald Trump’s June 30, 2025, executive order “Providing for the Revocation of Syria Sanctions” (EO 14312) is designed to finish the job. Effective July 1, 2025, EO 14312:
Revokes six foundational EOs on which the Syria sanctions program is based, delisting and unblocking the property of the over 500 individuals and entities designated as Specially Designated Nationals solely pursuant to those EOs.
Waives the requirements to impose Syria export controls under the Syria Accountability and Lebanese Sovereignty Restoration Act (the Syria Accountability Act) and the Chemical and Biological Weapons Control and Warfare Elimination Act (the CBW Act).
Directs the secretary of state to take “all appropriate action” with respect to the designation of Hay’at Tahrir al-Sham (HTS) — the group that led the coalition that ultimately toppled the Assad regime — and its leader, Syrian President Ahmad al-Sharaa, under terrorism-related authorities, and Syria’s designation as a State Sponsor of Terrorism.
Further directs the secretary of state to determine whether to continue to waive the imposition of sanctions under the Caesar Act’s secondary sanctions provisions, which the secretary of state had already suspended for 180 days pursuant to a waiver issued May 23, 2025.
Waives the sanctions imposed under the CBW Act on the provision of foreign assistance to Syria and the extension of certain loans and credit to the government of Syria.
OFAC will also remove the Syrian Sanctions Regulations (31 C.F.R. part 542) from the Code of Federal Regulations, though OFAC will maintain sanctions on certain members of the Assad family and their associates, human rights abusers, narcotics traffickers and other destabilizing actors in the region under the new Promoting Accountability for Assad and Regional Stabilization Sanctions (PAARSS) program.
Treasury Secretary Scott Bessent described these actions as intended to help Syria “reestablish ties to global commerce and build international confidence,” while continuing to prevent “Assad, his cronies, terrorists, and other illicit actors from attempting to destabilize Syria and the region.” Together with similar actions taken to date by the EU and U.K., we expect the U.S. government’s decision to lift sanctions and related restrictions will provide significant relief to the government and people of Syria and those looking to invest in Syria’s reemergence on the global stage.
Lifting of Syria-Related Sanctions
As outlined in our June 3 Alert, GL 25 provided significant sanctions relief by authorizing a host of activities otherwise prohibited by OFAC’s Syria Sanctions program. Notwithstanding this relief, there continued to be risk in engaging with Syria while the sanctions themselves (and certain related restrictions) remained in effect, and OFAC could revoke GL 25 at any time. EO 14312 addresses this risk by rescinding six EOs underlying OFAC’s Syria Sanctions program and terminating the national emergency established and expanded in those EOs. As a result, OFAC has delisted more than 500 individuals and entities that were designated solely pursuant to those authorities, removed the Syrian Sanctions Regulations and replaced the former Syria Sanctions program with the new list-based PAARSS program.
The PAARSS program includes EO 14312 and an amended EO 13894, pursuant to which OFAC has designated former President Bashar al-Assad, certain members of his family and their associates, officials of the former Assad regime that have not expressed support for Syria’s new government, persons who provided material support to the former Assad regime, human rights abusers, drug traffickers, and other persons that have engaged in destabilizing activities in Syria and the broader region. OFAC has also re-designated certain targets of the former Syria Sanctions program under its Iran and Counter Terrorism programs. OFAC noted in a frequently asked question.1
The revocation of the Syrian Sanctions Regulations removes prohibitions on new investment in Syria, the provision of services to Syria, transactions involving Syria-origin oil, petroleum and certain other energy products, and other activities previously covered by the regulations. This relief is not retroactive, however, and OFAC may pursue enforcement action in response to violations of the Syrian Sanctions Regulations that occurred before EO 14312 became effective July 1, 2025.
Impact on Export Controls
EO 14312 is also likely to lead to a removal or significant relaxation of the comprehensive export controls currently in place with respect to Syria. Currently, a license is required to export or reexport all items subject to the Export Administration Regulations (EAR) to Syria other than food and medicine classified as EAR99, and there is a general policy of denial for such license applications.
In revoking EO 13338, which prohibited the exportation of certain goods to Syria, and waiving requirements to impose certain export controls under the Syria Accountability Act and the CBW Act, the Trump administration has cleared a path for the Commerce Department’s Bureau of Industry and Security (BIS) (which has primary jurisdiction over the export of most items to Syria) to lessen or eliminate the strict export controls currently in place. BIS has not issued amendments to its regulations or guidance in response to EO 14312 as of the date of this alert. Until it does, the comprehensive U.S. export controls applicable to Syria remain in place. We expect the Commerce Department to issue updated guidance on its implementation of EO 14312 in the near term.
Other Actions
EO 14312 addresses other components of the restrictions that have historically prohibited or significantly circumscribed the ability of U.S. and non-U.S. persons to engage in activities involving Syria.
EO 14312 waives restrictions under the CBW Act on the provision of foreign assistance by the U.S. government to Syria; the provision of credit, credit guarantees or other financial assistance by the U.S. government to Syria; and the extension of loans or credit by U.S. financial institutions to the government of Syria. The waivers become effective within 20 days of transmittal by the secretary of state to Congress.
As noted in our June 3 Alert, the State Department issued on May 23, 2025, a 180-day waiver of the secondary sanctions in the Caesar Act, which authorize the U.S. government to impose blocking sanctions or visa restrictions on foreign persons that engaged in certain specified sanctionable activities. The May 23 waiver remains in effect, and EO 14312 directs the secretary of state to continue to examine whether Syria has satisfied the criteria for such waiver. The exceptive relief issued by the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) in connection with its rule imposing special measures against the Commercial Bank of Syria under Section 311 of the USA PATRIOT Act also remains in place.
Lastly, EO 14312 directs the secretary of state, in consultation with the secretary of the Treasury and the attorney general, to “take all appropriate action” with respect to the designation of HTS as a Foreign Terrorist Organization, as well as the State Department’s designation of President al-Sharaa as a Specially Designated Global Terrorist. HTS was a leading element of the opposition forces that toppled the Assad regime in December 2024 and formed the current transitional government of Syria under President al-Sharaa. EO 14312 also directs the secretary of state to review Syria’s designation as a state sponsor of terrorism, which triggers a number of restrictions on the provision of financial and military assistance to Syria and various export controls restrictions. We expect these designations will be reversed in line with the Trump administration’s policy vis-à-vis Syria.
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1 See OFAC, Frequently Asked Question 1223 (June 30, 2025).
