Recent Developments on Sanctions on Syria in the UK, EU and US

Following the fall of the Assad regime, the UK, EU and US have announced a relaxation of their respective sanctions regimes against Syrian entities and individuals. Key sanctions and trade prohibitions have been lifted to reflect the change in Syrian leadership. However, various restrictions remain in force and so any companies considering whether to resume or launch operations in Syria should carefully consider the current sanctions picture and remain alive to ongoing developments.

uk sanctions on syria

Background:

The UK has maintained comprehensive sanctions on Syria through the Syria (Sanctions) (EU Exit) Regulations 2019 (the "UK Regulations") throughout the Assad regime. The UK Regulations aimed to place economic pressure on the regime to end human rights abuses and oppression of the civilian population, through a mixture of financial sanctions (including asset freezes, investment and banking-related restrictions) and trade sanctions in a number of sectors.

Which UK sanctions are being lifted?

In February 2025, the UK government announced that sanctions will be relaxed to promote security and stability in Syria.

On 6 March 2025, 24 Syrian entities were de-listed as designated persons, including the Central Bank of Syria, Syrian Arab Airlines and various Syrian oil companies. A further 12 entities were de-listed on 24 April 2025, including the Syrian Ministry of Defence, Ministry of Interior and media companies.

The Syria (Sanctions) (EU Exit) (Amendment) Regulations 2025 ( "Amending Regulations"), were subsequently published on 25 April 2025 and took effect the same day. The Explanatory Memorandum to the Amending Regulations explains that sanctions on key sectors (including energy, transport and financial services) are being lifted with the aim of promoting peace, stability and the rule of law in Syria. In particular, the Amending Regulations remove prohibitions in relation to:

• Import of crude oil and petroleum products which originate or have been consigned from Syria;
• Investment in crude oil and electricity production;
• Various activities in the financial sector, including for example establishing a correspondent banking relationship with Syrian financial institutions;
• Provision of insurance services to the Syrian regime (as defined); and
• Export, supply or delivery of aviation fuel, goods and technology relating to crude oil and natural gas, goods relating to electricity production, and bank notes or coinage (and the provision of ancillary services).

Which UK sanctions remain in place?

Although sanctions on several key Syrian entities have been lifted, 348 designated persons (almost all individuals) remain subject to asset freezes. The sanctions that remain in place aim to ensure that the UK Regulations are "fit for purpose" and maintain accountability for human rights violations committed during the Assad regime.

From a financial sector perspective, the previous restrictions on dealing in Syrian bonds have been narrowed to apply only to Assad-era bonds (issued between 19 January 2012 and 8 December 2024), but this sub-set of restrictions remains in force.

The Amending Regulations also maintain trade prohibitions on trade in:

• gold, precious metals and diamonds;
• military / internal repression goods and technology;
• interception and monitoring good and services; and
• the export of goods relating to chemical and biological weapons.

In respect of the continuing Syria asset freeze, OFSI General Licence INT/2025/5810196 (the "GL") remains available to permit activities necessary to provide humanitarian assistance or support basic human needs in Syria. Any companies seeking to rely on the GL should ensure that they have carefully considered its terms and comply with the GL's notification requirements.

The UK's future plans for sanctions on Syria:

The UK government has not announced plans for any further relaxations of sanctions on Syria. However, it has pledged £160 million to support Syria's economic recovery and stability post-Assad. This pledge accompanies other efforts to support a political transition which prioritises human rights. In a joint statement with the EU, the USA, Turkey and the Arab Contact Group on Syria, the UK affirmed its commitment to protecting access to humanitarian aid and expressed support for a "Syrian-led and Syrian-owned" political transition.

eu sanctions on syria

Background:

In May 2011, the European Union ("EU") suspended all its bilateral cooperation with the government of Syria and its supporters due to the intensifying violence and severe human rights violations. For over a decade, between 2011 and 2024, the EU imposed a comprehensive sanctions framework targeting the Al-Assad regime, including individuals and key sectors of the Syrian economy. These measures were primarily enacted through Regulation (EU) No 36/2012 ("Regulation 36/2012"), which has been amended multiple times.

The sanctions introduced under Regulation 36/2012 were wide-ranging and included:

• A freezing of the assets of and travel bans for over 350 individuals and over 90 entities ("EU Designated Persons");
• A freezing of the assets of the Syrian Central Bank within the EU, with a ban on making funds or economic resources available but an allowance for legitimate trade to continue under strict conditions;
• An import ban on arms and related material from Syria;
• Export restrictions on certain equipment, goods and technology that might be used for internal repression or for the monitoring or interception of internet or telephone communications;
• Export restrictions on certain luxury goods to Syria;
• A requirement for EU Member States to inspect vessels and aircraft if there are reasonable grounds to believe they carry arms, related material or equipment that might be used for internal repression;
• A prohibition on Syrian financial institutions opening new branches or subsidiaries in the EU or establishing new joint ventures or new correspondent banking relationships with EU banks;
• An import ban on crude oil and petroleum products from Syria and on any financing, insurance or reinsurance in their regard, as well as a ban on investment in the Syrian oil industry; and
• A ban on investment in companies engaged in the construction of new power plants for electricity production in Syria.

EU Sanctions being lifted:

Following the fall of the Assad regime in December 2024, the European Council reassessed the sanctions framework and agreed to a phased easing aimed at “reviving the Syrian economy and supporting the country’s recovery.”

As a first step, on 24 February 2025, the European Council suspended a number of restrictive measures on Syria's key economic sectors. In particular, Regulation 36/2012 was amended (see the amending regulations here and here) with the effect of:

• Suspending sectoral measures in energy (including oil, gas and electricity) and transport sectors;
• Removing five entities (including financial institutions and Syrian Arab Airlines) from the list of EU Designated Persons;
• Allowing making funds and economic resources available to the Syrian Central Bank (although its assets remained frozen);
• Allowing certain banking transactions related to energy, transport, and humanitarian needs;
• Extending the existing, and introducing further, exemptions in relation to the activities necessary for humanitarian purposes; and
• Introducing an exemption in relation to the prohibition on export of luxury goods to Syria, where such export is for personal use of persons travelling from the EU and is not intended for sale in Syria.

On 28 May 2025, the European Council then lifted nearly all remaining sectoral sanctions on Syria. In particular, in addition to delisting 24 entities from the list of EU Designated Persons (now including the Syrian Central Bank), the EU has also completely lifted most other previously applicable sectoral restrictions (see the amending regulation here). The European Council stated that the lifting was "the right thing to do, at this historic time, for the EU to genuinely support Syria’s recovery and a political transition that fulfils the aspirations of all Syrians."

EU Sanctions remaining in place:

Several key restrictions remain in place, including:

• Security-related measures, including the arms embargo and export controls on equipment that could be used for internal repression;
• The designation of individuals and entities linked to the Assad regime, which has been extended until 1 June 2026; and
• New listings under the EU Global Human Rights Sanctions Regime in response to the violence in Syria in March 2025, targeting two individuals and three entities for serious human rights violations.

To support Syria’s transition and reconstruction, the EU has pledged nearly EUR 2.5 billion for the years 2025 and 2026. This is expected to also address urgent humanitarian needs within Syria and in host communities across Jordan, Lebanon, Iraq, and Türkiye. More recently, the EU announced an additional EUR 175 million to support Syria’s social and economic recovery, including investments in key industrial sectors, education, healthcare, justice, and accountability.

us sanctions on syria

On May 23, 2025, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued Syria General License No. 25 (“GL 25”), titled “Authorizing Transactions Prohibited by the Syrian Sanctions Regulations or Involving Certain Blocked Persons.” This general license authorizes a broad range of transactions that were previously prohibited under the Syrian Sanctions Regulations, 31 C.F.R. Part 542, essentially suspending the US embargo against Syria. See our previous post for further context on previous US Sanctions on Syria.

Subject to the limitations set forth below, GL 25 authorizes the following:

• Transactions otherwise prohibited under the Syrian Sanctions Regulations (31 C.F.R. Part 542), excluding those involving persons whose property and interests in property remain blocked (except as specified in the annex to GL 25);
• Transactions involving the Government of Syria that are currently prohibited under existing sanctions regulations; and
• Transactions involving certain sanctioned persons listed in the annex to GL 25, as well as entities in which one or more of those listed persons directly or indirectly hold a 50 percent or greater ownership interest. These entities include, but are not limited to, the Central Bank of Syria, major state-owned enterprises, port and maritime authorities, financial institutions, and media and tourism-related entities.

GL 25 does not authorize:

• Transactions involving individuals or entities listed on the Specially Designated Nationals and Blocked Persons List, except for those specifically identified in the annex to GL 25, or entities owned 50 percent or more, directly or indirectly, by such persons;
• The unblocking of any property or interests in property that were blocked pursuant to any sanctions regulations as of May 22, 2025; and
• Transactions conducted for or on behalf of the Governments of the Russian Federation, the Islamic Republic of Iran, or the Democratic People’s Republic of Korea; (iv) transactions involving the transfer or provision of goods, technology, software, funds, financing, or services, unless otherwise explicitly authorized.

Additionally, we note that some persons and entities in Syria remain subject to US blocking sanctions, and that GL 25 does not amend or supersede any existing export control measures imposed under the International Traffic in Arms Regulations or the Export Administration Regulations.

Lastly, in conjunction with the issuance of GL 25, the U.S. Department of State issued a 180-day waiver of mandatory Caesar Act sanctions to further facilitate investment in key sectors of the Syrian economy. Further, the Financial Crimes Enforcement Network also provided relief under the USA Patriot Act, allowing U.S. financial institutions to open and maintain correspondent accounts for the Commercial Bank of Syria.