Status update: EU and UK easing of sanctions on Syria

White & Case LLP
Contact

White & Case LLP

On 23 June 2025, the EU Council approved a new set of conclusions on Syria, confirming the EU's support for the country's peaceful transition and its engagement with the transitional government to facilitate Syria's economic recovery.1 To this end, the EU recently lifted a majority of its sanctions against Syria. The UK has also recently eased its sectoral sanctions against Syria. Both the EU and the UK have removed various Syria-related entities and individuals from their respective asset freeze lists, although a significant number of designations remain. Below, we provide a status update on the EU and UK easing of sanctions against Syria.

Recent lifting of EU and UK sanctions against Syria

Following the fall of the Assad regime in December 2024, the EU2 and UK3 have eased their sanctions targeting Syria to take account of the changing political situation. The key EU and UK sanctions against Syria that have been lifted relate to the following categories:

Energy sector measures

The EU and UK previously maintained broad sanctions targeting Syria's energy sector, including oil, gas, and electricity supply and production. This included an EU export ban on listed equipment or technology related to oil and gas exploration, production, refining, or liquefaction, or used for the construction or installation in Syria of new power plants for electricity production; restrictions on financing Syrian parties involved in crude oil exploration, production, refining, or the construction and installation of new power plants; and a ban on any import, purchase, or transport of Syria-related crude oil or petroleum products. These EU restrictions have all now been lifted, and the UK has also lifted similar sanctions measures targeting Syria's energy sector.

Both the EU and UK have also removed from their respective asset freeze lists various entities engaged in the production or supply of oil, gas and other petroleum products. This includes, amongst others, the EU and UK de-listing of the Syrian Petroleum Company, the Syrian Trading Oil Company (Sytrol), the General Petroleum Corporation (GPC), and the Syrian Company for Oil Transportation.

Certain import and export restrictions

The EU has lifted its prohibitions on the sale, supply, transfer or export of Syrian denominated banknotes and coinage, jet fuel, fuel additives and luxury goods in relation to Syria. The EU now also permits both the export to Syria and import from Syria of gold, precious metals and diamonds.

Whilst the UK has also removed its export restrictions relating to jet fuel and fuel additives, as well as Syrian denominated banknotes and coinage, it has not lifted corresponding trade sanctions against Syria relating to luxury goods and gold, precious metals and diamonds, all of which remain in place.

Financial services

The EU has also lifted various financial services measures in relation to Syria, including in relation to the provision of insurance and re-insurance to the Syrian government. Previously, the financial services sanctions prohibited (amongst other things) disbursements or payments under existing loan agreements between the European Investment Bank and the State of Syria and related technical assistance services, dealings with Syrian public or public-guaranteed bonds, and the provision of a range of financial services to Syrian credit or financial institutions (such as the establishment of new correspondent banking relationships).

The UK has similarly lifted all sanctions relating to investments, financial services and financial markets, with the exception of the UK prohibition on the sale or purchase of bonds (and related services); the UK bond-related prohibition has been amended so that it now only applies to bonds issued by the Assad regime or guaranteed by the Assad regime and issued between 19 January 2012 and 8 December 2024.

Transport

Both the EU and UK have removed sanctions that previously prohibited cargo flights operated by Syrian carriers or flights operated by Syrian Arab Airlines from accessing airports in the EU and UK, respectively.

Asset Freeze

Amongst a range of asset freeze de-listings, the EU and UK have removed various State-owned entities in Syria, such as the Central Bank of Syria and Syrian Arab Airlines. The UK (unlike the EU) has also removed certain Syrian government entities such as the Ministry of Interior and Ministry of Defence from the respective asset freeze lists.

Which EU and UK sanctions remain in place?

Whilst there has therefore been a significant easing of EU and UK sanctions against Syria, not all measures have been lifted. The key EU and UK sanctions that remain in place fall under the following categories:

Asset Freezes and travel bans

A large number of Syrian individuals and entities remain subject to the EU and/or UK asset freeze restrictions (and travel bans, where applicable). It is therefore important to continue to screen all Syria-related parties against the EU and UK sanctions lists.

For now, the EU has maintained more than 350 names on the EU asset freeze list deemed as being responsible for violent repression against the civilian population in Syria or who have benefited from or supported the Assad regime. The UK maintains asset freezes against a similar number of persons.

Importantly, the current transitional President Al-Sharaa (aka Abu Mohammed Al-Jawlani), and other members of the transitional Syrian government, at present remain designated under both EU and UK sanctions.4

Trade restrictions

The EU also retains targeted trade sanctions against Syria (including on certain related assistance/services) based on security grounds, namely:

  • an arms embargo;
  • restrictions on any direct or indirect sale, supply, transfer or export of listed items involving (a) internal repression goods and technology; and (b) equipment, technology or software which may be used for monitoring or intercepting internet or telephone communications; and
  • prohibitions on the import, export, transfer or provision of brokering services in relation to Syrian cultural property goods and similar items (with limited exceptions).

Individual EU Member States may also still prohibit or impose a special authorisation requirement (i.e. on top of general dual-use export licensing requirements) on any export to Syria of dual-use items, and any provision of equipment which might be used for internal repression (i.e. even if the equipment in question is not specifically listed in the EU sanctions regulation).

The UK has similarly retained trade sanctions (also targeting certain associated assistance/services) that relate to internal repression goods and technology; interception and monitoring goods, technology, and services; goods and technology relating to chemical and biological weapons (including certain dual-use goods and technology); and military goods and technology. In addition, the UK (unlike the EU) has maintained its sanctions relating to gold, precious metals, diamonds, luxury goods, as well as limited restrictions on Assad-era bonds, as noted above.5

Prospect of further relaxation of EU and UK sanctions

It is unclear at this stage whether there will be a further relaxation of UK and/or EU sanctions, including to more closely align the asset freeze lists of the two jurisdictions or UK trade sanctions with those of the EU. The UK and EU have also emphasised that the easing of sanctions on Syria are reversible and depend on the actions of the Syrian transitional government. Given the inconsistencies and potential for further changes, it is therefore important for businesses to pay close attention to developments relating to Syria and continue to perform related compliance checks, including sanctions screening of Syria-related parties, in order to ensure compliance with relevant sanctions regimes.

1 See Council conclusions on Syria, 23 June 2025.
2 Recent amendments to the EU's Syria sanctions regime (imposed under EU Regulation 36/2012) have been adopted through Council Implementing Regulation 2025/1094 and Council Regulation 2025/1098. Relevant sanctions were suspended by the EU as of 26 February 2025 (through Council Regulation 2025/407), and then lifted as of 29 May 2025.
3 Recent changes to the UK's Syria sanctions regime were made through amendments to the Syria (Sanctions) (EU Exit) Regulations 2019.
4 See the consolidated list of persons, groups and entities subject to EU financial sanctions and the UK Sanctions List.
5 This is under The Syria (United Nations Sanctions) (Cultural Property) (EU Exit) Regulations 2020.

[View source.]

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

© White & Case LLP

Written by:

White & Case LLP
Contact
more
less

PUBLISH YOUR CONTENT ON JD SUPRA NOW

  • Increased visibility
  • Actionable analytics
  • Ongoing guidance

White & Case LLP on:

Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide
- hide