Building on prior relief of sanctions and other restrictive trade measures earlier this year (as described in K2 Integrity alerts dated 15 May and 09 June 2025), on 30 June 2025, U.S. President Donald Trump issued a new Executive Order (EO), EO 14312, “Providing for the Revocation of Syria Sanctions.”[1] EO 14312 terminates the broad Syria sanctions program, effective 1 July 2025, and directs various U.S. government agencies to remove additional restrictions to the extent permitted by law.
Per the EO, the U.S. administration has seen positive developments in Syria under the new government of President Ahmed al-Sharaa and wants to continue to support Syria’s path towards a stable state.
EO 14312 marks a material shift in U.S. sanctions policy toward Syria, terminating the broad prohibitions targeting Syria that have been in place since the early 2000s. While the comprehensive, country-based program has been revoked, the EO retains a limited set of sanctions targeting former Syrian president Bashar al-Assad, his regime, and former government officials; persons engaging in destabilizing activities such as undermining the stability of Syria, supporting terrorism, or engaging in the production and smuggling of the drug Captagon; Iranian proxies; human rights abusers; and enablers and material supporters of any of the above.
Summary of the New EO
The EO ends the national emergency with respect to Syria and revokes six previous EOs that authorized various Syria sanctions prohibitions.[2] The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has removed the Syria Sanctions Regulations (SySR) from the Code of Federal Regulations, replacing it with a more targeted Promoting Accountability for Assad and Regional Stabilization Sanctions program (PAARSS).[3] Consistent with the prior OFAC actions terminating a sanctions program, this termination does not affect pending or future OFAC investigations or enforcement actions related to potential violations of the Syria Sanctions Regulations that occurred prior to 1 July 2025.[4]
OFAC has clarified in its FAQs that the previously issued General License 25 (GL 25) remains in place and persons can continue to rely on its provisions, since its authorizations were broader than activity prohibited solely under the SySR.[5]
In addition, the EO directs the U.S. Secretary of State to:
- Evaluate to what extent the U.S. State Department should suspend the imposition of sanctions under the Caesar Syria Civilian Protection Act of 2019 (the Caesar Act);
- Review the designation of President Ahmed al-Sharaa as a Specially Designated Global Terrorist (SDGT) and the designation of Hay’at Tahrir al-Sham (HTS), the rebel group that was the major force behind ousting President Assad and that has become a de facto governing authority, as a Foreign Terrorist Organization (FTO) and SDGT;
- Review Syria’s designation as a State Sponsor of Terrorism; and
- Explore avenues for sanctions relief at the UN to support stability in Syria.
On 7 July 2025, the U.S. State Department announced that it revoked the designation of HTS as an FTO, effective the following day, due to the Syrian government’s commitment to combating terrorism.[6]
Separately, in the EO President Trump made a determination under Section 5(a)(1) of the Syria Accountability and Lebanese Sovereignty Restoration Act of 2003 (the Syria Accountability Act) that it is in the national security interest of the United States to waive the prohibition on exports of any items on the U.S. Commerce Control List (i.e., U.S. origin dual-use items) to Syria. Pursuant to this waiver, the U.S. Department of Commerce will now need to revise relevant regulations in the Export Administration Regulations (EAR) to replace such prohibitions with more appropriate export control restrictions.
Prohibitions or Obligations That Remain in Place
Targeted Blocking Sanctions
As noted above, OFAC has now implemented the new Promoting the Accountability for Assad and Regional Stabilization Sanctions (PAARSS) Program. This program is based on the designation authorities of EO 13891 of 14 October 2019 (“Blocking Property and Suspending Entry of Certain Persons Contributing to the Situation in Syria”), as amended by EO 14312. Specifically, under this authority OFAC can continue to designate:
- Former officials of the Assad regime or persons acting for or on their behalf;
- Persons threatening the peace, security, or stability of Syria;
- Persons engaged in activities or transactions related to Captagon;
- Persons providing material support to the former Assad regime or to an SDN;
- Persons owned or controlled or acting on behalf of an SDN; or
- Adult family members of certain SDNs.
Overall, OFAC has removed 518 individuals and entities from the List of Specially Designated Nationals and Blocked Persons (the SDN List) previously listed under various Syria authorities and simultaneously (re)designated 139 persons under the above-stated criteria and several other sanctions programs such as Iran.[7] For persons removed from the SDN List, all their property and interests in property become unblocked.
Secondary Sanctions
Several types of sanctions on Syria or its supporters are mandated under congressional acts, e.g., the Caesar Act of 2019, the Syria Accountability Act of 2003, and the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (the CBW Act). The president cannot terminate these acts but instead has to rely on various suspension or waiver authorities under each to provide sanctions relief and submit periodic reports to Congress explaining the waivers.
The Caesar Act is the basis for secondary sanctions designations, i.e., targeting by the U.S. State Department of foreign persons that support or otherwise engage in certain activity with Syria or its government. The Caesar Act allows the president to continuously suspend imposition of any new sanctions under the Act for renewable periods of 180 days, with accompanying reports to Congress. In EO 14312 the president directed the Secretary of State to consider whether such suspension, in whole or in part, is warranted.
This expands on prior relief in May, when U.S. Secretary of State Marco Rubio announced that the United States will not impose secondary sanctions for most of Syria-related activity, with the exception of sanctionable transactions with certain SDNs and transactions for or on behalf of the governments of Russia, North Korea, or Iran or transfer of goods, technology, or software to or from these countries.[8] Finally, pursuant to the mandates in EO 14312, on 30 June Secretary of State Rubio waived the sanctions previously imposed on 10 individuals and entities under the Act.[9]
Export Controls
All export control restrictions on Syria under the EAR remain in place until the Department of Commerce amends the regulations. The president effectively granted Commerce such authority by choosing to waive the relevant provisions of the Syria Accountability Act and the CBW Act and directing the Secretary of State to submit the required reports to Congress.
Until the State Department submits the reports and Commerce implements the necessary EAR amendments, only U.S.-origin food and medicine designated as EAR99, as well as a few types of items benefiting from narrow license exceptions such as items used by the news media or the U.S. government, can be exported to Syria. Export of all other items subject to the EAR requires a license from Commerce.[10] This license requirement applies to all U.S.-origin items subject to the EAR, whether designated as dual-use or EAR99. This affects activities of all persons around the world dealing with U.S.-origin goods, as EAR jurisdiction follows a good, software, or technology no matter when and how it was exported or re-exported from the United States.
State Sponsor of Terrorism Designation
Syria also remains a country designated as a State Sponsor of Terrorism (SST), although EO 14312 directs the Secretary of State to reconsider such designation. An SST designation involves the following restrictions, among others:
- A ban on arms-related exports and sales;
- Controls over exports of dual-use items, with some such exports requiring congressional approval;
- Prohibitions on economic assistance and requirement on the United States to oppose any loans by the World Bank and other international financial institutions;
- Denial of duty-free treatment of goods exported from the SST to the United States;
- Lifting of the SST’s sovereign immunity to allow terrorism victims and their families to sue an SST in U.S. courts;
- The authority (but not the requirement) to prohibit any U.S. citizen from engaging in a financial transaction with the SST country without OFAC license; and
- Prohibition on U.S. Department of Defense contracts above $100,000 with companies controlled by the SST.[11]
Finally, under the CBW Act, the president chose to waive several sanctions imposed on Syria for its use of chemical weapons under the regime of Bashar al-Assad. Among others, the president waived restrictions on various types of U.S. government assistance, including credit and other financial assistance, to Syria and restrictions forbidding U.S. banks to provide loans to the Government of Syria. However, prohibitions on U.S. economic assistance remain in place under the SST designation, as noted above.
Key Takeaways
Despite some progress in Syria and the new government’s willingness to restore the country’s stability, Syria remains a complex and high-risk environment.
Be Aware of Restrictions that Remain. While OFAC lifted the broad countrywide sanctions, targeted blocking and secondary sanctions remain in place. Therefore, it is crucial to conduct thorough due diligence to ensure contemplated activities and transactions do not involve any parties on the SDN List; persons 50% or more owned by blocked persons; the Iranian, North Korean, or Russian governments; or persons acting as a front for any of the above.
Furthermore, HTS, one of the major forces behind the ousting of Bashar al-Assad and a key player in the Syrian transitional government, remains on the SDN list and is also subject to asset freeze sanctions mandated by the UN. Despite reports that HTS may have been dissolved recently, it remains unclear whether engaging in business with the Syrian government may lead to the de facto support of a group that remains a globally designated terrorist organization.
Finding a Financial Partner Can Be Challenging. While OFAC removed all Syrian banks from the SDN list and the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) provided exceptive relief allowing U.S. banks to open and maintain correspondent accounts for the Commercial Bank of Syria, as discussed in our 9 June alert, many global financial institutions may remain cautious and continue to prohibit Syria-related activity as a matter of internal policy, at least for some time. Banks also can continue to prohibit Syria-related activity due to the fact that Syria appears on the Grey List maintained by the Financial Action Task Force (FATF). It is thus crucial to understand the policies of your banking partners prior to attempting to process any Syria-related transactions.
If You Decide to Proceed, Proceed with Caution. Companies that decide to explore opportunities in Syria should implement detailed compliance programs as well as consider drafting exit plans should the situation deteriorate. As evidenced by past occurrences, U.S. sanctions relief can become permanent, as in the case with Libya, or the U.S. government can reimpose broad restrictions, as was the case with Burma/Myanmar and Sudan. In addition, as described above, some U.S. Syria sanctions are mandated by Congress and have to be periodically waived by the president. The president may decide not to renew a waiver should Syria or its government fail to progress towards a stable state and reintegration into international community.
Broader Opportunities Exist for NGOs and Charitable Activities. The elimination of the SySR, the waiver of secondary sanctions under the Caeser Act, the UN humanitarian exemption under the Al-Qaida sanctions regime, and the existence of GL 25 open new paths for NGOs to operate in Syria, especially in the areas of humanitarian aid, reconstruction, and civil society support. However, NGOs are subject to the same restrictions described above and therefore should implement detailed compliance policies and analyze their activity to ensure compliance with regulations imposed by the United States and other countries of relevance to their activity.
[1] Executive Order 14312 of 30 June 2025, “Providing for the Revocation of Syria Sanctions,” available at https://ofac.treasury.gov/media/934411/download?inline.
[2] Specifically, E.O. 13338 of 11 May 2004; E.O. 13399 of 25 April 2006; E.O. 13460 of 13 February 2008; E.O. 13572 of 29 April 2011; E.O. 13573 of 18 May 2011; and E.O. 13582 of 17 August 2011.
[3] OFAC’s official page for PAARSS Program is at https://ofac.treasury.gov/sanctions-programs-and-country-information/paarss.
[4] See OFAC FAQ 1220, available at https://ofac.treasury.gov/faqs/added/2025-06-30.
[5] See OFAC FAQ 1223, available at https://ofac.treasury.gov/faqs/added/2025-06-30
[6] The U.S. Department of State, Press Statement, “Revoking the Foreign Terrorist Organization Designation of Hay’at Tahrir al-Sham,” available at https://www.state.gov/releases/office-of-the-spokesperson/2025/07/revoking-the-foreign-terrorist-organization-designation-of-hayat-tahrir-al-sham.
[7] OFAC made the new designations under the authorities of the EO 13894 of 14 October 2019, as further amended by EO 14312.
[8] The U.S. Department of State, Caesar Act Waiver Certification, 23 May 2025, available at https://www.state.gov/caesar-act-waiver-certification/.
[9] Termination of Syria Sanctions, Fact Sheet, the U.S. Department of State, 30 June 2025, available at https://www.state.gov/releases/2025/06/termination-of-syria-sanctions/.
[10] Bureau of Industry and Security, Syria Export Controls Overview, available at https://www.bis.gov/licensing/country-guidance/syria-export-controls.
[11] The U.S. Department of State, Annual Country Report on Terrorism, 2006, Chapter 6 – State Sponsors of Terror Overview, available at https://2009-2017.state.gov/j/ct/rls/crt/2005/64337.htm.