Client Alert: May 23, 2025
Syria Sanctions Relaxed: After U.S. President Donald Trump verbally announced on May 13, 2025, that he would lift the United States’ long-standing sanctions on Syria, after 10 days, on Friday, May 23, 2025, the Office of Foreign Assets Controls (OFAC) at the U.S. Department of the Treasury issued General License (GL) No. 25 authorizing all transactions for U.S. persons otherwise prohibited under the Syria Sanctions Regulations (“SSR”, 31 C.F.R. Part 542), except for transactions with blocked persons (e.g. SDNs).
GL 25 specifically authorizes transactions with the Government of Syria as well as entities listed in the Annex to GL 25 or those majority owned by those listed in the Annex. However, GL 25 does not authorize any transaction for or on behalf of the Governments of Russia, Iran and North Korea as well as the transfer or provision of goods, technology, software, funds, financing or services to or from Russia, Iran, and North Korea.
It is the general policy of OFAC to not enforce secondary sanctions on non-U.S. persons for transactions for which U.S. persons are authorized. However, in this case, there is a carve out from this policy for those transactions involving the Governments of Russia, Iran or North Korea, as well as goods, technology, financing and services between Syria and Russia, Iran, North Korea.
In addition, a General License can be revoked by OFAC at any time without prior notice. Despite President Trump’s statement that he will lift U.S. sanctions on Syria, the General License provides only a preliminary easing of sanctions on Syria. In addition to revising the SSR, prior Executive Orders issued to implement sanctions on Syria, such as E.O. 13582, 13338, 13399, 13460, 13572, 13573, 13606, etc. would need to be revoked by President Trump for an actual “lifting” of the sanctions. Lifting of certain U.S. sanctions on Syria imposed by the U.S. Congress through legislation such as the Syria Human Rights Accountability Act of 2012, CAATSA, or the Caesar Syria Civilian Protection Act of 2019, would presumably also require Congressional action.
Transactions with these entities which were previously sanctioned are now authorized under GL 25 as listed in its Annex:
SYRIAN ARAB AIRLINES
SYTROL
AL-JAWLANI, Abu Muhammad
KHATTAB, Anas Hasan
COMMERCIAL BANK OF SYRIA
CENTRAL BANK OF SYRIA
GENERAL PETROLEUM CORPORATION
SYRIAN COMPANY FOR OIL TRANSPORT
SYRIAN GAS COMPANY
SYRIAN PETROLEUM COMPANY
REAL ESTATE BANK
GENERAL ORGANIZATION OF RADIO AND TV
BANIAS REFINERY COMPANY
HOMS REFINERY COMPANY
AGRICULTURAL COOPERATIVE BANK
INDUSTRIAL BANK
POPULAR CREDIT BANK
SAVING BANK
GENERAL DIRECTORATE OF SYRIAN PORTS
LATTAKIA PORT GENERAL COMPANY
SYRIAN CHAMBER OF SHIPPING
SYRIAN GENERAL AUTHORITY FOR MARITIME TRANSPORT
SYRIAN SHIPPING AGENCIES COMPANY
TARTOUS PORT GENERAL COMPANY
PUBLIC ESTABLISHMENT FOR REFINING AND DISTRIBUTION
SYRIAN MINISTRY OF PETROLEUM AND MINERAL RESOURCES
SYRIAN MINISTRY OF TOURISM
FOUR SEASONS DAMASCUS
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