The sudden collapse of the Assad regime in Syria has led to a rapidly evolving sanctions landscape. Notably, on January 6, 2025, the United States relaxed sanctions on certain transactions with Syria when the Office of Foreign Assets Control (OFAC) issued Syria General License 24 (GL 24), “Authorizing Transactions with Governing Institutions in Syria and Certain Transactions Related to Energy and Personal Remittances.” While this general license relaxes some of the long-standing U.S. sanctions, companies must keep in mind that the United Kingdom and the European Union currently maintain robust sanctions on Syrian energy-related transactions. At the date of publication, there have been no official publications by the UK or the EU on a change of their stance on this.
Valid through July 7, 2025, Syria General License 24 in pertinent part authorizes:
- transactions with governing institutions[1] in Syria following December 8, 2024;
- transactions in support of the sale, supply, storage, or donation of energy, including petroleum, petroleum products,[2] natural gas, and electricity to or within Syria.
That said, there are significant carve-outs to the authorizations permitted under GL 24, and many of the U.S. sanctions against Syria remain in place.[3] For example, GL 24 only covers energy transactions “to or within Syria.” Other relevant restrictions that are still in place:
- U.S. persons/non-U.S. persons using U.S. dollars are still prohibited from engaging in “new investment” in Syria. The term is defined as “a commitment or contribution of funds or other assets.”
- Practically, this means U.S. persons/non-U.S. persons using U.S. dollars would generally be prohibited from providing financing for or assisting in the development of oil projects in Syria.
- However, contributions of funds for salaries or wages of employees of governing institutions in Syria are permitted to the extent payments are not made to persons blocked pursuant to the Syrian Sanctions Regulations (SySR), the Global Terrorism Sanctions Regulations (GTSR), and the Foreign Terrorist Organizations Sanctions Regulations (FTOSR) unless explicitly authorized or, as relevant here, for the purpose of effecting the payment to governing institutions in Syria for taxes, fees, or import duties or the purchase or receipt of permits, licenses, public utility services, or other public services in Syria.
- The importation into the United States of petroleum or petroleum products of Syrian origin is prohibited.
- Transactions related to the provision of Russian-origin or Iranian-origin goods, technology, software, funds, financing, or services to Syria are prohibited.
- Accordingly, even if the Russian-origin product is price cap compliant, it cannot be transferred to Syria.
- Many entities and individuals in Syria that are on the Specially Designated Nationals and Blocked Persons List are still blocked.
- Having a U.S. nexus to transactions with SDNs is prohibited and, even without a U.S. nexus, OFAC may pursue secondary sanctions on non-U.S. persons in certain instances. Thus, due diligence would still be required and each transaction must be reviewed.
Distinct from the sanctions restrictions that remain, export controls still apply, where the U.S. Department of Commerce Bureau of Industry and Security prohibits the export or reexport of any U.S.-origin items, other than food or medicine classified as EAR99, to Syria.
Finally, the EU and UK regimes continue to maintain their own sanctions programs against Syria. Overall, the EU and UK asset freeze restrictions currently remain in place against a number of entities (including those associated with the oil industry), so transactions with Syria would likely still face practical challenges to the extent there is an EU/UK nexus. Substantive due diligence across the entire transaction chain is required to ensure there are no relevant asset freeze targets involved.
[1] Transactions with the new government in Syria are allowed despite Specially Designated National (SDN) individuals having leadership roles in its institutions (see FAQ 1208). Practically, the fact that the government institutions are not considered sanctioned notwithstanding the sanctioned leadership may be relevant in certain scenarios, such as when paying customs duties to the Syrian authorities or dealing with certain ports. A carve-out, however, is that transactions involving military or intelligence entities, or any persons acting for or on behalf of such entities, are still prohibited.
[2] What constitutes “petroleum products” has not been enumerated specifically in the context of the Syria sanctions; however, OFAC has provided them in the context of the Iran sanctions to include “unfinished oils, liquefied petroleum gases, pentanes plus, aviation gasoline, motor gasoline, naphtha-type jet fuel, kerosene-type jet fuel, kerosene, distillate fuel oil, residual fuel oil, petrochemical feedstocks, special naphthas, lubricants, waxes, petroleum coke, asphalt, road oil, still gas, and miscellaneous products obtained from the processing of: crude oil (including lease condensate), natural gas, and other hydrocarbon compounds. The term does not include natural gas, liquefied natural gas, biofuels, methanol, and other non-petroleum fuels.” See FAQ 620.
[3] Syria is still among the U.S. list of State Sponsors of Terrorism (SST). The main categories of sanctions resulting from SST designation include restrictions on U.S. foreign assistance; a ban on defense exports and sales; certain controls over exports of dual use items; and miscellaneous financial and other restrictions. In addition, it implicates other sanctions laws that penalize persons and countries engaging in certain trade with state sponsors.