Overview

On May 13, 2025, President Donald Trump announced during a speech at an investment forum in Riyadh, Saudi Arabia, that the U.S. intends to lift longstanding sanctions on Syria. President Trump remarked that the lifting of sanctions would give Syria “a fresh start,” but has not yet provided a timeline for the lifting. The announcement follows the fall of the Assad regime and the installation of a new transitional government led by Ahmed al-Sharaa, a former opposition figure. President Trump cited the departure of the Assad regime as a justification for easing economic pressure, framing the move as a step toward regional stabilization and economic recovery.

Background of U.S. Sanctions on Syria

The U.S. has maintained comprehensive, embargo-level sanctions on Syria for over a decade, targeting the previous Assad regime for human rights abuses, support for terrorism, and use of chemical weapons. The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) administers comprehensive sanctions against Syria under various executive orders. Notably, Executive Order 13582 creates an effective embargo, which prohibits U.S. persons from: (i) engaging in new investments in Syria; (ii) the direct or indirect exportation, reexportation, sale, or supply of any services to Syria from the U.S. or by a U.S. person; (iii) importing petroleum or petroleum products of Syrian origin into the U.S.; (iv) transacting, in or related to, petroleum or petroleum products of Syrian origin; and (v) approving, financing, facilitating, or guaranteeing a transaction by a foreign person where the transaction would be prohibited if performed by a U.S. person or within the U.S. These restrictions are codified in 31 CFR part 542.

The Trump Administration’s decision marks a significant shift in U.S. foreign policy, signaling a willingness to re-engage diplomatically and economically with Syria under new leadership. The announcement was made during a broader Middle East tour by President Trump, which included stops in Qatar, Saudi Arabia and the UAE. It is important to note that at the time of this post, the lifting of U.S. sanctions on Syria has not been formally implemented.  Until this occurs, the relevant sanctions remain fully in effect, and it is not clear whether all U.S. sanctions restrictions would be lifted or subject to what conditions. 

Impact of Previous Sanctions

Previous U.S. sanctions programs were implemented to respond to actions of the former Assad regime, and have had profound impacts on Syrian citizens. For example, U.S. sanctions have impacted the ability of NGOs and individuals to send humanitarian aid. Further, major fundraising platforms and payment processors have suspended transactions to Syria, citing U.S. sanctions compliance concerns, resulting in frozen accounts and delayed aid.

Sanctions have also restricted access to digital services and platforms, including educational and professional tools like Google, Amazon, and Zoom, further isolating Syrians from global opportunities. Certain video game platforms were also forced to block Syrian users due to broad restrictions on digital services.

U.S. sanctions have also contributed to shortages of medical supplies and pharmaceuticals, particularly for critical treatments such as cancer care, due to restrictions on imports and the complex licensing requirements for humanitarian exemptions.

Following the 2023 Turkey–Syria earthquakes, these barriers became even more apparent, as fundraising efforts were blocked until temporary sanctions relief was granted. We discussed U.S. sanctions exemptions related to humanitarian efforts in Syria in a previous blog post on February 10, 2023.

Implications and Next Steps

For businesses and financial institutions, the potential lifting of sanctions could open new opportunities. However, until formal regulatory changes are issued by OFAC, existing restrictions remain in place. We advise companies to closely monitor official guidance and to refrain from engaging in prohibited transactions until sanctions are formally lifted. While we anticipate a lifting of most of the Executive Orders imposing sanctions on Syria, we note that there are numerous SDNs, including designated government officials, in the country that may continue to pose potential concerns from a U.S. sanctions liability perspective.

For the most up to date information from OFAC on U.S. sanctions programs imposed on Syria, we advise readers to refer to the following link.

***

We will continue to monitor developments in this area and encourage you to subscribe to be kept informed of the latest updates. Please contact the authors or your usual Herbert Smith Freehills contacts for more information.

Related categories

Jonathan Cross Christopher Boyd Yash Dattani Nikita Jhunjhunwala