GL 25 opens up investment across the Syrian economy, but particularly in the Syrian energy sector.
GL 25 and the accompanying press statement are designed to “enable new investment and private sector activity consistent with the President’s America First strategy.” In doing so, GL 25 authorizes:
- The provision of services to people and companies in Syria;
- New investment in Syria;
- The import of or dealing in petroleum and petroleum products from Syria;
- Transactions with the new Government of Syria, including entities owned 50% of more by the Government of Syria;
- Transactions involving certain blocked persons and entities, including Syria’s interim President Ahmed al-Sharaa (aka Abu Muhammad Al-Jawlani), which are listed in the Annex to GL 25, and any entities owned 50% or more by such blocked entities.
Further, while the Trump Administration states that “GL 25 will facilitate activity across all sectors of the Syrian economy,” it is clear from the terms of GL 25 that the energy sector of the Syrian economy is the initial focus of sanctions relief. This energy focus advances previous OFAC policies under the Biden Administration which issued GL 24 on January 6, 2025 (fourteen days prior to the transition to the Trump Administration), authorizing transactions with the Syrian Government that were “in support of the sale, supply, storage, or donation of energy, including petroleum, petroleum products, natural gas, and electricity, to or within Syria.” In short, where GL 24 permitted providing foreign energy-related supplies and services to Syria, GL 25 permits investment in Syria’s own energy resources while also covering all authorizations under GL24, effectively replacing and expanding it.
The majority of licensed entities in the Annex to GL 25 are entities involved in the petroleum extraction and shipping industry, including eight petroleum companies and related regulatory agencies, eight maritime shipping companies and related regulatory agencies, and seven banks.
Petroleum Sector Authorizations:
- Sytrol
- General Petroleum Corporation
- Syrian Gads Company
- Syrian Petroleum Company
- Banias Refinery Company
- Homs Refinery Company
- Public Establishment for Refining and Distribution
- Syrian Ministry of Petroleum and Mineral Resources
Shipping Sector Authorizations:
- Syrian Company for Oil Transport
- 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 or Refining and Distribution
Banking Sector Authorizations:
- Commercial Bank of Syria
- Central Bank of Syria
- Real Estate Bank
- Agricultural Cooperative Bank
- Industrial Bank
- Popular Credit Bank
- Savings Bank
The US Department of State waives secondary sanctions under the Caesar Act.
Alongside GL 25, the US Department of State issued a 180 day waiver under the Caesar Syria Civilian Protection Act (Caesar Act) to further promote investment in Syria. The Caesar Act authorizes the Sec. of Treasury in consultation with the Sec. of State to block any foreign person that engages in significant transactions or provides significant goods, services, technology, information, or other support to the Government of Syria. By waiving these prohibitions, the State Department waived secondary sanctions with respect to foreign entities transacting with the Government of Syria.
Because the Caesar Act is a congressionally mandated sanctions regime, fully lifting Syria sanctions across the board requires Congress to repeal or amend the Caesar Act. Nevertheless, the Caesar Act gives the President broad authority to renew Caesar Act waivers every 180 days as long as the President determines a waiver is required “in the national security interests of the United States,” effectively giving the President authority to continually renew Caesar Act waivers indefinitely.
Companies looking to invest in Syria must remain diligent to avoid violating the terms of GL 25 or the Caesar Act waiver.
US Anti-Terrorism Statutes and Entities Not Listed in the Annex to GL 25:
GL 25 does not lift all sanctions on Syria, instead it provides an exception to sanctions prohibitions for the entities listed on the Annex to GL 25. This distinction has two main effects: (1) the US Government retains the power to reimpose sanctions on Syria simply by revoking GL 25 and the Caesar Act waiver, and (2) companies investing in Syria must avoid any transactions that touch sanctioned entities which are not listed in the Annex to GL 25. For example, Hayat Tahrir al-Sham (HTS)—associated with the new Syrian Government—is a designated foreign terrorist organization (FTO) and an SDN. Likewise, Syria’s former leader Bashar al-Assad is still listed as an SDN. As a result, companies operating in Syria must ensure their transactions do not involve or benefit HTS, Bashar al-Assad, or other blocked entities not listed in the Annex to GL 25. Failure to do so could result in violations of US antiterrorism statutes and/or sanctions regulations.
Iran and Russia Sanctions:
Iran and Russia have historically maintained close ties to Syria under the Assad regime, providing the country supplies of petroleum and other services in the past. In fact, OFAC issued an advisory in September 2024 concerning the sanctions risks related to Iran and Russia operating in Syria, stating “countries such as Iran and Russia have continued to provide petroleum shipments to the Government of Syria.” Assuming Iran and Russia continue to operate in Syria, companies investing in Syria will need to ensure their transactions do not run afoul of Iran or Russia sanctions.
Export Embargo Remains for Now.
GL 25 does not remove export control restrictions under the Export Administration Regulations (EAR) or the International Traffic in Arms Regulations (ITAR). Under the EAR a Commerce Department license is required for the export or reexport to Syria of all items subject to EAR jurisdiction, “except food and medicine classified as EAR99.” The export of defense articles to Syria is prohibited and subject to a licensing policy of denial under the ITAR.
