President Trump has ended the broad U.S. sanctions embargo on Syria, but sanctions against certain designated targets remain in place. As of July 1, 2025, Executive Order 14312:
- Rescinds the Treasury Department’s Office of Foreign Assets Control (“OFAC”) economic sanctions program regarding Syria;
- Targets certain persons tied to the Assad regime and other destabilizing regional actors with sanctions; and
- Authorizes the lifting of the export embargo on Syria as implemented under the Export Administration Regulations.
President Trump also announced changes to strengthen the Cuba sanctions program, reversing actions by President Biden near the end of his term.
Changes to Syria Sanctions: A Closer Look
1. Termination of Comprehensive Sanctions on Syria
Effective July 1, Executive Order 14312 rescinds sanctions against Syria in their current form by: revoking a 2004 executive order on which the sanctions were based, terminating the national emergency declared in that order, and revoking subsequent executive orders based on that national emergency. This action had the effect of terminating broad prohibitions on exporting services to Syria, making new investments in Syria, and conducting business involving the Government of Syria.
OFAC concurrently:
- Announced that it would remove the Syrian Sanctions Regulations from the Code of Federal Regulations, and that the Syria-related sanctions program would become the Promoting Accountability for Assad and Regional Stabilization Sanctions program;
- Removed 518 individuals and entities from the List of Specially Designated Nationals and Blocked Persons (“SDN List”) that had been sanctioned under the Syria sanctions program; and
- Released frequently asked questions clarifying the scope of its actions.
Notably, OFAC removed all Syrian financial institutions from the SDN List, including the Central Bank of Syria, and clarified that U.S. financial institutions are permitted to establish relationships with financial institutions in Syria and export financial services to Syria.
2. Expansion of Certain Targeted Sanctions Related to Syria
Executive Order 14312 maintains, and in some cases expands, sanctions on the Assad family and former government officials of the Assad regime, persons involved in the illicit captagon trade, and persons in Syria involved in the commission of serious human rights abuses or in threats to the peace, security, stability or territorial integrity of Syria.
OFAC designated 139 individuals and entities under the amended executive order, Iran sanctions programs and counterterrorism-related sanctions programs.
3. Potential Suspension of Sanctions Required Under the Caesar Act
The Caesar Syria Civilian Protection Act of 2019 authorizes secondary sanctions against foreign persons that engage in certain activities related to Syria (See our prior Orrick alert). Executive Order 14312 directs the Secretary of State and Secretary of the Treasury to review whether Syria meets the criteria for suspending sanctions under the Caesar Act, and, if so, to brief Congress and implement the suspension. The Secretary of State must continue monitoring Syria’s compliance with the required suspension conditions and reimpose sanctions if Syria fails to meet those obligations. On May 23, 2025, the Secretary of State had previously issued a 180-day waiver of sanctions under the Caesar Act that remains in effect.
4. Authorization to Waive Certain Export Controls
Executive Order 14312 also authorizes the easing of certain export controls imposed under the Syria Accountability and Lebanese Sovereignty Restoration Act of 2003, and certain export controls imposed under the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991.
The Bureau of Industry and Security of the Commerce Department (“BIS”), which administers U.S. export controls on items exported to Syria, has not yet implemented these changes. On July 8, 2025, BIS sent a final rule to the Office of Management and Budget for interagency review. Until BIS publishes this rule, the existing controls (which require a license or other authorization to export or reexport to Syria any item that is subject to the Export Administration Regulations, except for food and medicine) will remain in effect.
5. Changes to and Further Review of Syria-related Counterterrorism Designations
On July 8, 2025, the Secretary of State revoked the Foreign Terrorist Organization designation of the al-Nusrah Front. The Secretary will also review the designation of the al-Nusrah Front and Abu Muhammad al-Jawlani (commonly known as Ahmed al-Sharaa) as Specially Designated Global Terrorists and of Syria as a State Sponsor of Terrorism.
6. Prior Syria Sanctions Relief: General License 25
On May 23, 2025, OFAC issued Syria General License (“GL”) 25, which had the effect of authorizing, by way of exception, many of the now-revoked prohibitions under the Syria sanctions program. The GL authorized dealings with blocked parties that were listed in an Annex to the GL.
On June 30, 2025, OFAC clarified that U.S. persons can continue to rely on GL 25 for transactions involving persons listed in the Annex to GL 25 that are otherwise prohibited by certain other sanctions programs.
Strengthening Restrictions on Cuba
On June 30, 2025, President Trump reissued and amended National Security Presidential Memorandum / NSPM-5 relating to Cuba. President Biden had revoked the memorandum on January 15, 2025.
The amended memorandum directs the heads of certain executive departments and agencies to take the following actions, among others:
- By July 30, 2025, initiate a process to adjust regulations regarding transactions with Cuba, such that transactions with entities that are controlled by or act for or on behalf of the Cuban military, intelligence, or security services or personnel are generally prohibited;
- By July 30, 2025, initiate a process to adjust regulations to ensure adherence to the statutory ban on tourism to Cuba;
- Regularly audit travel to Cuba;
- Expand the definition of “prohibited officials of the Government of Cuba” for purposes of the Cuban Assets Control Regulations; and
- Convene a task force, composed of relevant agencies, non-governmental organizations, and private-sector entities, to examine the technological challenges and opportunities for expanding internet access in Cuba.
Recommendations for Companies and Individuals
- Even if your business does not currently operate in Syria, secondary sanctions under the Caesar Act may impact dealings with foreign partners or vendors that do. Closely monitor for possible new sanctions on Syria, should the U.S. administration determine that Syria has failed to maintain required conditions of the Caesar Act;
- Evaluate the applicability of other restrictions on business with Syria, such as sanctions and export controls of other jurisdictions, and review contractual representations or commitments to third parties to refrain from such activity;
- Ensure compliance with U.S. export controls on Syria, particularly before BIS implements easing; and
- If you rely on existing authorizations to conduct business or travel involving Cuba, the scope of these authorizations is likely to diminish. Expect increased scrutiny and possible rollback of permitted activities. Plan ahead for potential disruptions as the administration signals a stricter enforcement posture.
Shruthi Maganti (Summer Associate) contributed to this article.
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