U.S. Sanctions on Syria

Last updated November 3, 2025

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Which mechanisms has the Trump administration used to modify or waive U.S. sanctions on Syria?

 

Have most U.S. sanctions on Syria been lifted?

Yes, the Trump administration has lifted most U.S. sanctions on Syria, including some that had been in place for over two decades.

 

Which EOs did EO 14312 revoke?

EO 14312 revoked:

  • EO 13338, “Blocking Property of Certain Persons and Prohibiting the Export of Certain Goods to Syria” (May 13, 2004);
  • EO 13399, “Blocking Property of Additional Persons in Connection With the National Emergency With Respect to Syria” (April 28, 2006);
  • EO 13460, “Blocking Property of Additional Persons in Connection With the National Emergency With Respect to Syria” (February 13, 2008);
  • EO 13572, “Blocking Property of Certain Persons With Respect to Human Rights Abuses in Syria” (April 29, 2011);
  • EO 13573, “Blocking Property of Senior Officials of the Government of Syria” (May 20, 2011); and
  • EO 13582, “Blocking Property of the Government of Syria and Prohibiting Certain Transactions With Respect to Syria” (August 17, 2011).
 

Which U.S. sanctions on Syria remain in place or have been expanded?

The Trump administration has left in place or expanded sanctions targeting:

  • Officials of the former Assad regime;
  • Human rights violators;
  • Those involved in weapons of mass destruction (WMD) proliferation;
  • Al-Qaeda and ISIS affiliates;
  • Those involved in trafficking captagon; and
  • The Iranian regime and its proxies.
 

What happened to OFAC’s Syria Sanctions Regulations?

As a result of EO 14312, OFAC has removed the Syria Sanctions Regulations from the Code of Federal Regulations. Remaining sanctions targeting Syrian persons and entities now fall under OFAC’s Promoting Accountability for Assad and Regional Stabilization Sanctions Program (PAARSS).

 

Does EO 13894, “Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Syria” (October 14, 2019), remain in force?

Yes. EO 14312 expanded the scope of the national emergency declared in EO 13894, including targeting new groups for sanctions, such as:

  • “[Those] responsible for or complicit in, [or] ha[ve] directly or indirectly engaged in, or attempted to engage in, or financed the obstruction, disruption, or prevention of efforts to promote a Syria that is stable, unified, and at peace with itself and its neighbors”;
  • “[Those found] to be responsible for or complicit in, or to have directly or indirectly engaged in, or attempted to engage in . . . actions or policies that further threaten the peace, security, stability, or territorial integrity of Syria; or . . . the commission of serious human rights abuse”;
  • Former Assad regime officials or persons “who acted for or on behalf of such” officials;
  • Those who “have engaged in, or attempted to engage in, activities or transactions that have materially contributed to, or pose a significant risk of materially contributing to, the illicit production and international illicit proliferation of captagon”;
  • Those found to be involved in or responsible for instances in which U.S. nationals or lawful permanent residents “went missing in Syria” during the Assad regime’s rule; and
  • Those found “to have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of” the Assad regime, the aforementioned activities, or persons whose property is blocked pursuant to EO 13894.
 

Does the U.S. still designate the Islamist extremist group Hayat Tahrir al-Sham (HTS) as a Foreign Terrorist Organization (FTO) and as a Specially Designated Global Terrorist (SDGT)?

Secretary Rubio revoked the FTO designation of HTS, a.k.a. al-Nusrah Front, effective July 8, 2025. However, HTS remains a designated SDGT. President Trump, in EO 14312, had directed Secretary Rubio to “take all appropriate action with respect to the designation of” HTS as an FTO and an SDGT.

 

Does the U.S. still designate Syrian Interim President Ahmed al-Sharaa as an SDGT?

Yes. President al-Sharaa, a.k.a. Abu Muhammad al-Jawlani, remains a designated SDGT. President Trump, in EO 14312, had directed Secretary Rubio to “take all appropriate action with respect to the designation of” al-Sharaa as an SDGT.

 

What are the legal consequences of the SDGT designation have?

With regard to SDGTs, EO 13224 (with limited exceptions) blocks their “property or interests in property that are in the United States or come within the United States, or that come within the possession or control of U.S. persons.”

Further, with limited exceptions, “any transaction or dealing by U.S. persons or within the United States in property or interests in property blocked pursuant to [EO 13224] is prohibited, including but not limited to the making or receiving of any contribution of funds, goods, or services to or for the benefit of individuals or entities designated under the [EO].” Likewise, “Any transaction by any U.S. person or within the United States that evades or avoids, or has the purpose of evading or avoiding, or attempts to violate, any of the prohibitions in [EO 13224] is prohibited. Any conspiracy formed to violate any of the prohibitions is also prohibited.”

 

Does the U.S. continue to designate Syria as a State Sponsor of Terrorism (SSOT)?

Yes. President Trump, in EO 14312, had directed Secretary Rubio to “take all appropriate action to review the designation of Syria as [an SSOT].”

 

Are many legal restrictions on exports to Syria now lifted?

Yes. EO 14312, by waiving provisions of the Syria Accountability and Lebanese Sovereignty Restoration Act, lifted the ban on the export to Syria of any item on the Commerce Control List, as well as the ban on the export of American products to Syria.

Further, by waiving provisions of the Chemical and Biological Weapons and Warfare Elimination Act, the EO lifted the ban on U.S. foreign aid; ended the denial of U.S. government credit, credit guarantees, or other financial assistance; lifted the ban on the export of national security-sensitive goods and technology and all other goods and technology; and lifted the ban on U.S. banks making loans or providing credit.

 

Has the Trump administration authorized transactions with the Syrian government, its officials, and select other leading Syrian entities?

On May 23, 2025, OFAC issued GL 25, which authorizes all transactions banned by the Syria Sanctions Regulations, the Weapons of Mass Destruction Proliferators Sanctions Regulations, the Iranian Financial Sanctions Regulations, the Global Terrorism Sanctions Regulations, the Foreign Terrorist Organizations Sanctions Regulations, or Executive Order 13574 involving:

  • The Syrian government;
  • Syrian President Ahmed al-Sharaa (referred to in the GL as Abu Muhammad al-Jawlani);
  • Syrian Interior Minister Anas Hasan Khattab;
  • Syrian Ministry of Petroleum and Mineral Resources;
  • Syrian Ministry of Tourism;
  • Syrian Arab Airlines;
  • Sytrol;
  • Commercial Bank of Syria;
  • Central Bank of Syria;
  • General Petroleum Corporation;
  • Syrian Company for Oil Transport;
  • Syrian Gas Company;
  • Real Estate Bank;
  • General Organization of Radio and TV;
  • Banias Refinery Company;
  • Homs Refinery Company;
  • Agricultural Cooperative Bank;
  • Industrial Bank;
  • Popular Credit Bank;
  • Saving Bank;
  • General Directorate of Syrian Ports;
  • Lattakia Port General Company;
  • Syrian Chamber of Shipping;
  • Syrian General Authority for Maritime Transport;
  • Syrian Shipping Agencies Company;
  • Tartous Port General Company;
  • Public Establishment for Refining and Distribution; and
  • Four Seasons Damascus.

Further, on June 30, 2025, coinciding with the issuance of EO 14312, Secretary Rubio lifted or waived sanctions on a number of persons or entities. Specifically, Rubio:

  • Waived sanctions under the Caesar Syria Civilian Protection Act with respect to:
    • Adam Trading and Investment LLC;
    • Wassim Anwar al-Qattan;
    • Khaled al-Zubaidi;
    • Intersection LLC;
    • Muruj Cham Investment and Tourism Group;
    • Apex Development and Projects LLC;
    • Nader Kalai;
    • Al-Amar One-Person LLC;
    • Timeet Trading LLC; and
    • Aleksey Makarov.
  • Terminated sanctions under EO 13894 on:
    • The First and Fourth Divisions of the Syrian Arab Army; and
    • The National Defense Forces.
  • Terminated sanctions under the Iran Sanctions Act on Sytrol.
 

What are examples of transactions authorized by GL 25?

According to an FAQ document released by OFAC, “Examples of authorized transactions under GL 25 include but are not limited to: telecommunications-related services; power grid infrastructure rehabilitation and other energy-related services; health care-related services; education-related services; agricultural-related services; civil-aviation and other transportation services; construction-related services; water and waste management-related services; and financial and investment services. U.S. banks are authorized to process transactions for any activities authorized by GL 25. U.S. persons and members of the Syrian diaspora community are authorized to provide support to the new Government of Syria.”

 

Has the Trump administration suspended sanctions on Syria under the Caesar Syria Civilian Protection Act of 2019?

No. In EO 14312, President Trump directed Secretary Rubio “to examine whether the criteria for suspension of sanctions under the Caesar Syria Civilian Protection Act have been met.” However, Secretary Rubio has yet to suspend sanctions, though he did waive some sanctions for 180 days effective May 23, 2025. The biggest practical difference between waiving and suspending sanctions—both of which can only be done for 180 days at a time—is that Secretary Rubio can only waive sanctions on a foreign person or group of persons, while a suspension can apply to part or all of the sanctions under the Act. Further, suspending sanctions could send a message to Congress that the Act should be repealed.

 

What are the conditions for suspending sanctions on Syria under the Caesar Syria Civilian Protection Act of 2019?

To suspend sanctions under that legislation, the following conditions must be met:

  • “The air space over Syria is no longer being utilized by the Government of Syria or the Government of the Russian Federation to target civilian populations through the use of incendiary devices, including barrel bombs, chemical weapons, and conventional arms (including air-delivered missiles and explosives)”;
  • “Areas besieged by the Government of Syria, the Government of the Russian Federation, the Government of Iran, or [a foreign person that is a military contractor, mercenary, or a paramilitary force knowingly operating in a military capacity inside Syria for or on behalf of one of those governments]”;
  • “The Government of Syria is releasing all political prisoners forcibly held within the prison system of the regime of Bashar al-Assad and the Government of Syria is allowing full access to prison system facilities for investigations by appropriate international human rights organizations”;
  • “The forces of the Government of Syria, the Government of the Russian Federation, the Government of Iran, and any foreign person [that is a military contractor, mercenary, or a paramilitary force knowingly operating in a military capacity inside Syria for or on behalf of one of those governments] are no longer engaged in deliberate targeting of medical facilities, schools, residential areas, and community gathering places, including markets, in violation of international norms”;
  • The Syrian government is:
    • “[T]aking steps to verifiably fulfill its commitments under the Chemical Weapons Convention and the Nuclear Non-Proliferation Treaty;
    • “[M]aking tangible progress toward becoming a signatory to the” Biological Weapons Convention;
    • “[P]ermitting the safe, voluntary, and dignified return of Syrians displaced by the conflict”; and
    • “[T]aking verifiable steps to establish meaningful accountability for perpetrators of war crimes in Syria and justice for victims of war crimes committed by the Assad regime, including through participation in a credible and independent truth and reconciliation process.”