This blog post was drafted with assistance from Sean C. Church, Paralegal
On August 28th, 2025, the Department of Commerce’s Bureau of Industry and Security (BIS) announced a final rule making changes to the Syria export control measures under the Export Administration Regulations (EAR). The rule, which is effective Tuesday, September 2, 2025, eases the existing restrictions on exports and reexports to Syria of items subject to the EAR. BIS made several changes in this rule, including revising certain license application review policies to be more favorable and expanding and adding license exceptions to apply to Syria.
The most notable amendments to the EAR by this rule include (but are not limited to) authorizing exports and reexports to Syria of all items designated EAR99 – the lowest level of classification, adopting a presumption of approval licensing policy for certain end uses, and the removal of now obsolete provisions in the EAR related to Syria. Consumer communications devices and certain items related to civil aviation may also generally go to Syria without an export license. BIS announced they will continue to restrict exports when the end-users of items are malign actors, including certain Syrian individuals and entities that remain subject to sanctions, noted below.
These changes to BIS’s policy toward Syria follow similar changes announced by the U.S. the Department of the Treasury’s Office of Foreign Assets Control (OFAC) earlier this summer, which implemented the President’s Executive Order “Providing for the Revocation of Syria Sanctions,” (Syria EO) which removed certain U.S. sanctions on Syria, effective July 1, 2025, while maintaining sanctions on former president Bashar Al-Assad, his associates, and other destabilizing regional actors under the Syria EO. Our blog post covering the OFAC Syria changes can be found here.
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