On May 23, the Office of Foreign Assets Control (OFAC) issued Syria General License 25, which authorizes a significant portion of previously prohibited transactions. The general license does not, however, amend or modify any of the existing Syria-related export controls under the International Traffic in Arms Regulations or Export Administration Regulations.
What does the general license authorize?
Subject to the limitations below, the general license authorizes:
- All transactions prohibited by the Syrian Sanctions Regulations, 31 C.F.R. Part 542 (other than those with blocked persons as described below).
- Transactions with the Syrian government[1] prohibited under existing sanctions regulations.
- Transactions prohibited under existing sanctions regulations with certain sanctioned persons listed in the annex to the general license, as well as any entity in which one or more of the persons listed in the annex directly or indirectly owns a 50% or greater interest. The entities listed in the annex include the Central Bank of Syria, major state-owned enterprises, port and maritime entities, other financial institutions, and media and tourism agencies and entities.
What does the general license not authorize?
The general license does not authorize:
- Any transactions involving any individual or entity on the Specially Designated Nationals and Blocked Persons List (SDN List) (other than those listed on the annex to the general license) or in which a sanctioned person owns, directly or indirectly, individually or in the aggregate, a 50% or greater interest.
- The unblocking of any property or interests in property blocked pursuant to any sanctions regulations as of May 22, 2025.
- Any transactions for or on behalf of the Russian, Iranian, or North Korean Government.
- Any transactions related to the transfer or provision of goods, technology, software, funds, financing, or services.
[1] The Syrian government includes: (a) the state and the Government of the Syrian Arab Republic, as well as any political subdivision, agency, or instrumentality thereof, including the Central Bank of Syria;
(b) any entity owned or controlled, directly or indirectly, by the foregoing, including any corporation, partnership, association, or other entity in which the Government of Syria owns a 50% or greater interest or a controlling interest, and any entity which is otherwise controlled by that government; (c) any person that is, or has been, acting or purporting to act, directly or indirectly, for or on behalf of any of the foregoing; and (d) any other person determined by OFAC to be included within paragraphs (a) through (c). 31 C.F.R. § 542.308.