On May 23, 2025, the U.S. Treasury Department, Office of Foreign Assets Control (OFAC) announced several actions to provide sanctions relief to Syria. OFAC is the primary government agency responsible for administering U.S. economic sanctions.
The measures authorize a broad range of transactions previously barred by U.S. sanctions, including dealings with the current government of Syria, thus opening the door to private‑sector activity in the country. At the same time, the United States maintains significant export restrictions on Syria, and compliance risks abound.
Authorizations
On May 23, OFAC issued Syria General License 25 (GL 25) to authorize all transactions prohibited by the Syrian Sanctions Regulations (SSR), other than those involving blocked persons. To provide additional guidance, on May 28 OFAC issued a series of Frequently Asked Questions related to the GL.
In particular, GL 25 authorizes all transactions with the current government of Syria, as well as with the 28 blocked persons listed on the Annex to the GL (the Annex), and with entities owned 50 percent or more by the persons on the Annex that are otherwise prohibited by the SSR or by certain other sanctions regimes. As a result, many previously prohibited transactions in and involving Syria are now authorized, including the provision of services to parties in Syria, new investment in Syria, the dealing in petroleum and related products from Syria, and transactions with the government of Syria. According to OFAC, GL 25 is “one part of a broader U.S. government effort to remove the full architecture of sanctions imposed on Syria…”
Concurrently, the U.S. Department of State issued a 180-day waiver to the Caeser Syria Civilian Protection Act (Caesar Act) suspending “secondary sanctions” on non-U.S. parties that engage in transactions authorized under GL 25. Secretary of State Marco Rubio stated the waiver will “facilitate the provision of electricity, energy, water, and sanitation, and enable a more effective humanitarian response across Syria.”
Finally, Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an exception to USA PATRIOT Act rules that targeted the Commercial Bank of Syria. U.S. financial institutions will now be able to open or maintain correspondent accounts for the bank.
Limitations
Neither the waiver nor GL 25 authorize transactions with blocked persons other than those listed in the Annex, nor is there authorization for transactions that involve Iran, North Korea, or Russia. Additionally, sanctions targeting the Assad regime – and covering parties not listed in the Annex – remain in place. Furthermore, GL 25 does not authorize the unblocking of any property or interest in property blocked under any sanctions regime administered by OFAC as of May 22, 2025.
Importantly, none of the actions announced to date ease the strict compliance obligations maintained under primary U.S. export controls: the Export Administration Regulations (EAR), which cover commercial or “dual use” items, and the International Traffic in Arms Regulations (ITAR), which cover defense articles and services.
Subject to limited exceptions, a license is required for the export, re-export, or in-country transfer of all items subject to the EAR to or within Syria. The Department of Commerce, which administers the EAR, has not yet announced any changes to the EAR with respect to Syria. While we expect restrictions to be eased, at present, virtually all exports of U.S.-origin items to Syria are prohibited without a license.
The restrictions under the ITAR are even broader, as the U.S. government maintains a comprehensive arms embargo on Syria. No changes to the ITAR relating to Syria are expected.
Even with eased sanctions, multiple restrictions and compliance challenges remain
More generally, the underlying regulatory and statutory framework of the sanctions remains in effect. Furthermore, Syria remains a State Sponsor of Terrorism, which imposes, among other limitations, restrictions on U.S. foreign assistance, and which requires Congressional involvement to rescind. Finally, GL 25 only authorizes transactions with the parties listed on the Annex (though these parties still remain sanctioned). However, many other parties in Syria are listed on U.S. sanctions-related restricted party lists (for example, the State Department list of Foreign Terrorist Organizations), including those with ties to the current Syrian government. Actions taken to date do not relieve restrictions on dealings with these parties.
Finally, even with the easing of sanctions, there are likely to be continuing commercial challenges when conducting business in Syria. Obtaining financing for authorized transactions may be difficult as U.S. and other international banks proceed cautiously in re-opening operations in and with Syria. Identifying permissible and reliable business partners will necessitate careful due diligence in light of the ongoing sanctions and the lack of functioning infrastructure in the country. And given the fragile state of Syria’s new government, although GL 25 does not have an expiration date, the United States may revoke it at any time with little or no warning based on how the situation in Syria develops.
