As anticipated, on June 30, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced the implementation of President Trump’s Executive Order, “Providing for the Revocation of Syria Sanctions.” This action adds to General License 25 and removes the broad U.S. sanctions previously in place against Syria and the former regime, while maintaining sanctions on former Syrian President Bashar al-Assad, and other actors responsible for destabilizing the region, by expanding the scope of Executive Order 13894.

The key developments include the following:

  • OFAC has removed 518 individuals and entities from the Specially Designated Nationals and Blocked Persons (SDN) List who were previously sanctioned only under the Syria program. This action unblocks their property and interests in property. The full list, which may be found here, but includes the Syrian Company for Oil Transport, the Central Bank of Syria, the Lattakia Port General Company, SYTROL, the Banias Refinery Company, and the Homs Refinery Company.
  • The Executive Order waives the requirements to impose certain export controls under the Syria Accountability and Lebanese Sovereignty Restoration Act of 2003 and the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 and immediately confirmed that the export of U.S.-origin food and medicine is permitted (see FAQ 1222). Previously, only U.S.-origin food and medicine classified as EAR99 under the Department of Commerce’s Export Administration Regulations (the EAR) could be exported to Syria without authorization.
  • New FAQs clarify, among other things, that establishing correspondent banking relationships with Syrian financial institutions is now permitted, meaning that U.S. dollars may now be used for sanctions and export control-compliant transactions.
  • Some targeted sanctions remain, where OFAC has designated 139 individuals and entities affiliated with the former Assad regime under E.O. 13894 (as amended), as well as under other Iran and Counter Terrorism authorities. Sanctions remain in place for Bashar al-Assad, his associates, human rights abusers, captagon traffickers, individuals linked to Syria’s past proliferation activities, ISIS and Al-Qa’ida affiliates, and Iran and its proxies.
  • The Department of State has announced that it will examine the potential full suspension of the now-temporarily suspended Caesar Act.

Note however that caution is still required where:

  • OFAC has announced that it may continue to investigate and enforce apparent violations of the Syrian Sanctions Regulations that occurred prior to July 1, 2025.
  • Certain entities will remain blocked under other sanctions programs. Accordingly, reliance on General License 25 may still be required in certain circumstances. See FAQ 1223 for more details here.
  • Comprehensive export controls remain in place under the EAR, despite the waiver of some requirements to impose export restrictions on Syria.
  • The EU and UK still have limited sanctions in place against Syria, meaning certain transactions may still be prohibited under their respective sanctions regimes, even if permitted under U.S. law.

Please contact a member of the Reed Smith team below should you have any questions.