Building on prior relief of sanctions and other restrictive
trade measures earlier this year (as described in K2 Integrity
alerts dated 15 May and 09 June 2025), on 30 June 2025, U.S. President
Donald Trump issued a new Executive Order (EO), EO 14312,
“Providing for the Revocation of Syria
Sanctions.”1 EO 14312 terminates the broad Syria
sanctions program, effective 1 July 2025, and directs various U.S.
government agencies to remove additional restrictions to the extent
permitted by law.

Per the EO, the U.S. administration has seen positive
developments in Syria under the new government of President Ahmed
al-Sharaa and wants to continue to support Syria’s path towards
a stable state.

EO 14312 marks a material shift in U.S. sanctions policy toward
Syria, terminating the broad prohibitions targeting Syria that have
been in place since the early 2000s. While the comprehensive,
country-based program has been revoked, the EO retains a limited
set of sanctions targeting former Syrian president Bashar al-Assad,
his regime, and former government officials; persons engaging in
destabilizing activities such as undermining the stability of
Syria, supporting terrorism, or engaging in the production and
smuggling of the drug Captagon; Iranian proxies; human rights
abusers; and enablers and material supporters of any of the
above.

Summary of the New EO

The EO ends the national emergency with respect to Syria and
revokes six previous EOs that authorized various Syria sanctions
prohibitions.2 The U.S. Department of the Treasury’s
Office of Foreign Assets Control (OFAC) has removed the Syria
Sanctions Regulations (SySR) from the Code of Federal Regulations,
replacing it with a more targeted Promoting Accountability for
Assad and Regional Stabilization Sanctions program
(PAARSS).3 Consistent with the prior OFAC actions
terminating a sanctions program, this termination does not affect
pending or future OFAC investigations or enforcement actions
related to potential violations of the Syria Sanctions Regulations
that occurred prior to 1 July 2025.4

OFAC has clarified in its FAQs that the previously issued
General License 25 (GL 25) remains in place and persons can
continue to rely on its provisions, since its authorizations were
broader than activity prohibited solely under the
SySR.5

In addition, the EO directs the U.S. Secretary of State
to:


Evaluate to what extent the U.S. State Department should
suspend the imposition of sanctions under the Caesar Syria Civilian
Protection Act of 2019 (the Caesar Act);

Review the designation of President Ahmed al-Sharaa as a
Specially Designated Global Terrorist (SDGT) and the designation of
Hay’at Tahrir al-Sham (HTS), the rebel group that was the major
force behind ousting President Assad and that has become a de
facto governing authority, as a Foreign Terrorist Organization
(FTO) and SDGT;

Review Syria’s designation as a State Sponsor of Terrorism;
and

Explore avenues for sanctions relief at the UN to support
stability in Syria.

On 7 July 2025, the U.S. State Department announced that it
revoked the designation of HTS as an FTO, effective the following
day, due to the Syrian government’s commitment to combating
terrorism.6

Separately, in the EO President Trump made a determination under
Section 5(a)(1) of the Syria Accountability and Lebanese
Sovereignty Restoration Act of 2003 (the Syria Accountability Act)
that it is in the national security interest of the United States
to waive the prohibition on exports of any items on the U.S.
Commerce Control List (i.e., U.S. origin dual-use items) to Syria.
Pursuant to this waiver, the U.S. Department of Commerce will now
need to revise relevant regulations in the Export Administration
Regulations (EAR) to replace such prohibitions with more
appropriate export control restrictions.

Prohibitions or Obligations That Remain in Place

Targeted Blocking Sanctions

As noted above, OFAC has now implemented the new Promoting the Accountability for Assad and
Regional Stabilization Sanctions (PAARSS) Program. This program
is based on the designation authorities of EO 13891 of 14 October
2019 (“Blocking Property and Suspending Entry of Certain
Persons Contributing to the Situation in Syria”), as amended
by EO 14312. Specifically, under this authority OFAC can continue
to designate:


Former officials of the Assad regime or persons acting for or
on their behalf;

Persons threatening the peace, security, or stability of
Syria;

Persons engaged in activities or transactions related to
Captagon;

Persons providing material support to the former Assad regime
or to an SDN;

Persons owned or controlled or acting on behalf of an SDN;
or

Adult family members of certain SDNs.

Overall, OFAC has removed 518 individuals and entities from the
List of Specially Designated Nationals and Blocked Persons (the SDN
List) previously listed under various Syria authorities and
simultaneously (re)designated 139 persons under the above-stated
criteria and several other sanctions programs such as
Iran.7 For persons removed from the SDN List, all their
property and interests in property become unblocked.

Secondary Sanctions

Several types of sanctions on Syria or its supporters are
mandated under congressional acts, e.g., the Caesar Act of 2019,
the Syria Accountability Act of 2003, and the Chemical and
Biological Weapons Control and Warfare Elimination Act of 1991 (the
CBW Act). The president cannot terminate these acts but instead has
to rely on various suspension or waiver authorities under each to
provide sanctions relief and submit periodic reports to Congress
explaining the waivers.

The Caesar Act is the basis for secondary sanctions
designations, i.e., targeting by the U.S. State Department of
foreign persons that support or otherwise engage in certain
activity with Syria or its government. The Caesar Act allows the
president to continuously suspend imposition of any new sanctions
under the Act for renewable periods of 180 days, with accompanying
reports to Congress. In EO 14312 the president directed the
Secretary of State to consider whether such suspension, in whole or
in part, is warranted.

This expands on prior relief in May, when U.S. Secretary of
State Marco Rubio announced that the United States will not impose
secondary sanctions for most of Syria-related activity, with the
exception of sanctionable transactions with certain SDNs and
transactions for or on behalf of the governments of Russia, North
Korea, or Iran or transfer of goods, technology, or software to or
from these countries.8 Finally, pursuant to the mandates
in EO 14312, on 30 June Secretary of State Rubio waived the
sanctions previously imposed on 10 individuals and entities under
the Act.9

Export Controls

All export control restrictions on Syria under the EAR remain in
place until the Department of Commerce amends the regulations. The
president effectively granted Commerce such authority by choosing
to waive the relevant provisions of the Syria Accountability Act
and the CBW Act and directing the Secretary of State to submit the
required reports to Congress.

Until the State Department submits the reports and Commerce
implements the necessary EAR amendments, only U.S.-origin food and
medicine designated as EAR99, as well as a few types of items
benefiting from narrow license exceptions such as items used by the
news media or the U.S. government, can be exported to Syria. Export
of all other items subject to the EAR requires a license from
Commerce.10 This license requirement applies to all
U.S.-origin items subject to the EAR, whether designated as
dual-use or EAR99. This affects activities of all persons around
the world dealing with U.S.-origin goods, as EAR jurisdiction
follows a good, software, or technology no matter when and how it
was exported or re-exported from the United States.

State Sponsor of Terrorism Designation

Syria also remains a country designated as a State Sponsor of
Terrorism (SST), although EO 14312 directs the Secretary of State
to reconsider such designation. An SST designation involves the
following restrictions, among others:


A ban on arms-related exports and sales;

Controls over exports of dual-use items, with some such exports
requiring congressional approval;

Prohibitions on economic assistance and requirement on the
United States to oppose any loans by the World Bank and other
international financial institutions;

Denial of duty-free treatment of goods exported from the SST to
the United States;

Lifting of the SST’s sovereign immunity to allow terrorism
victims and their families to sue an SST in U.S. courts;

The authority (but not the requirement) to prohibit any U.S.
citizen from engaging in a financial transaction with the SST
country without OFAC license; and

Prohibition on U.S. Department of Defense contracts above
$100,000 with companies controlled by the SST.11

Finally, under the CBW Act, the president chose to waive several
sanctions imposed on Syria for its use of chemical weapons under
the regime of Bashar al-Assad. Among others, the president waived
restrictions on various types of U.S. government assistance,
including credit and other financial assistance, to Syria and
restrictions forbidding U.S. banks to provide loans to the
Government of Syria. However, prohibitions on U.S. economic
assistance remain in place under the SST designation, as noted
above.

Key Takeaways

Despite some progress in Syria and the new government’s
willingness to restore the country’s stability, Syria remains a
complex and high-risk environment.

Be Aware of Restrictions that Remain. While
OFAC lifted the broad countrywide sanctions, targeted blocking and
secondary sanctions remain in place. Therefore, it is crucial to
conduct thorough due diligence to ensure contemplated activities
and transactions do not involve any parties on the SDN List;
persons 50% or more owned by blocked persons; the Iranian, North
Korean, or Russian governments; or persons acting as a front for
any of the above.

Furthermore, HTS, one of the major forces behind the ousting of
Bashar al-Assad and a key player in the Syrian transitional
government, remains on the SDN list and is also subject to asset
freeze sanctions mandated by the UN. Despite reports that HTS may
have been dissolved recently, it remains unclear whether engaging
in business with the Syrian government may lead to the de facto
support of a group that remains a globally designated terrorist
organization.

Finding a Financial Partner Can Be Challenging.
While OFAC removed all Syrian banks from the SDN list and the
Treasury Department’s Financial Crimes Enforcement Network
(FinCEN) provided exceptive relief allowing U.S. banks to open and
maintain correspondent accounts for the Commercial Bank of Syria,
as discussed in our 9 June alert, many global financial
institutions may remain cautious and continue to prohibit
Syria-related activity as a matter of internal policy, at least for
some time. Banks also can continue to prohibit Syria-related
activity due to the fact that Syria appears on the Grey List
maintained by the Financial Action Task Force (FATF). It is thus
crucial to understand the policies of your banking partners prior
to attempting to process any Syria-related transactions.

If You Decide to Proceed, Proceed with Caution.
Companies that decide to explore opportunities in Syria should
implement detailed compliance programs as well as consider drafting
exit plans should the situation deteriorate. As evidenced by past
occurrences, U.S. sanctions relief can become permanent, as in the
case with Libya, or the U.S. government can reimpose broad
restrictions, as was the case with Burma/Myanmar and Sudan. In
addition, as described above, some U.S. Syria sanctions are
mandated by Congress and have to be periodically waived by the
president. The president may decide not to renew a waiver should
Syria or its government fail to progress towards a stable state and
reintegration into international community.

Broader Opportunities Exist for NGOs and Charitable
Activities. The elimination of the SySR, the waiver of
secondary sanctions under the Caeser Act, the UN humanitarian
exemption under the Al-Qaida sanctions regime, and the existence of
GL 25 open new paths for NGOs to operate in Syria, especially in
the areas of humanitarian aid, reconstruction, and civil society
support. However, NGOs are subject to the same restrictions
described above and therefore should implement detailed compliance
policies and analyze their activity to ensure compliance with
regulations imposed by the United States and other countries of
relevance to their activity.

Footnotes

1 Executive Order 14312 of 30 June 2025, “Providing
for the Revocation of Syria Sanctions,” available at https://ofac.treasury.gov/media/934411/download?inline.

2 Specifically, E.O. 13338 of 11 May 2004; E.O. 13399 of
25 April 2006; E.O. 13460 of 13 February 2008; E.O. 13572 of 29
April 2011; E.O. 13573 of 18 May 2011; and E.O. 13582 of 17 August
2011.

3 OFAC’s official page for PAARSS Program is at https://ofac.treasury.gov/sanctions-programs-and-country-information/paarss.

4 See OFAC FAQ 1220, available at https://ofac.treasury.gov/faqs/added/2025-06-30.

5 See OFAC FAQ 1223, available at https://ofac.treasury.gov/faqs/added/2025-06-30

6 The U.S. Department of State, Press Statement,
“Revoking the Foreign Terrorist Organization Designation of
Hay’at Tahrir al-Sham,” available at https://www.state.gov/releases/office-of-the-spokesperson/2025/07/revoking-the-foreign-terrorist-organization-designation-of-hayat-tahrir-al-sham.

7 OFAC made the new designations under the authorities of
the EO 13894 of 14 October 2019, as further amended by EO
14312.

8 The U.S. Department of State, Caesar Act Waiver
Certification, 23 May 2025, available at https://www.state.gov/caesar-act-waiver-certification/.

9 Termination of Syria Sanctions, Fact Sheet, the U.S.
Department of State, 30 June 2025, available at https://www.state.gov/releases/2025/06/termination-of-syria-sanctions/.

10 Bureau of Industry and Security, Syria Export Controls
Overview, available at https://www.bis.gov/licensing/country-guidance/syria-export-controls.

11 The U.S. Department of State, Annual Country Report on
Terrorism, 2006, Chapter 6 – State Sponsors of Terror
Overview, available at https://2009-2017.state.gov/j/ct/rls/crt/2005/64337.htm.

The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.