GUIDE ยท SANCTIONS

Sanctions on Syria: what was lifted, and what remains

Relief arrived in layers over eighteen months rather than in one repeal, which is why the position is widely misunderstood in both directions. This page sets out the public record, dated and sourced.

THE SHORT ANSWER

The United States no longer maintains comprehensive sanctions on Syria. Executive Order 14312 removed the country programme in June 2025, and the Caesar Act was repealed in December 2025. But relief is not total: specific entity and individual designations remain in force, export controls were eased rather than removed, and the UK and EU are on their own timetables.

This is not a compliance opinion. It is a summary of the public record on the date shown. Screening, licensing, and transaction-level questions require qualified counsel in your own jurisdiction.
June 2025
Country programme revoked
Executive Order 14312
Dec 2025
Caesar Act repealed
FY2026 NDAA
In force
Named designations
OFAC SDN List, ongoing
Separate
UK and EU regimes
Check each consolidated list
OVERVIEW

Sanctions have shaped Syria’s economy for longer than most people assume. Measures were first imposed in 1979, expanded in 2004, intensified after 2011, and culminated in the Caesar Act in 2020. Each layer addressed a different concern, and over time they accumulated into a regime that made ordinary commerce with Syria effectively impossible for most international firms.

The dismantling has been as layered as the construction. That is the single most important thing to understand about the current position.

Because relief came through a sequence of general licences, an executive order, and finally a statutory repeal, there is no single document you can point to and say sanctions are over. There are instead several distinct questions: is the country programme still in force, is the Caesar Act still law, is my counterparty designated, does my product need an export licence, and what does my own government say. They have different answers.

This page exists because the gap between the legal position and the general understanding of it is unusually wide right now, and because the people most affected, Syrian businesses and the diaspora, are the least likely to have a sanctions lawyer on retainer.

The two common errors. One is assuming nothing has changed, which is now badly out of date. The other is assuming everything has, which is how firms end up dealing with designated parties. Both are expensive.

How it unfolded

The sequence, dated

Understanding the order matters, because each step did something different and several were conditional rather than permanent.

January 2025

General License 24

The first substantive easing after the change of government, authorising certain transactions that had previously been prohibited. A licence rather than a repeal, and therefore revocable.

Source: US Treasury, OFAC
May 2025

General License 25, and a Caesar Act suspension

Broader authorisation, accompanied by a 180-day suspension of the Caesar Act. At this stage the statute remained on the books; only its operation was paused.

Source: US Treasury, OFAC
30 June 2025

Executive Order 14312 revokes the country programme

The decisive step on the executive side. EO 14312 removed the comprehensive US sanctions programme on Syria, revoking the earlier orders that had underpinned it. The State Department's position from this point is that the United States no longer maintains comprehensive Syria sanctions.

Source: Executive Order 14312; US Department of State
November 2025

Tri-Seal Advisory on relief

Commerce, Treasury, and State issued joint guidance on sanctions and export-control relief, which is the most useful single document for understanding what the executive changes meant operationally.

Source: joint advisory, Commerce, Treasury and State
18 December 2025

The Caesar Act is repealed outright

Congress repealed the Caesar Syria Civilian Protection Act of 2019 in the FY2026 National Defense Authorization Act. Because the Caesar Act was statutory, only Congress could remove it, which is why this step mattered independently of the executive orders. Its repeal ended the authority for broad secondary sanctions on non-US persons dealing with Syria, and the repeal was unconditional.

Source: FY2026 NDAA; US Department of State
Continuing

Periodic certification requirements

The repeal was accompanied by an obligation on the President to report periodically to Congress on a set of specified conditions. This does not reimpose sanctions, but it is the mechanism through which policy could be revisited, and it is why we describe the relief as durable rather than irreversible.

Source: FY2026 NDAA, post-repeal certification provisions
Status board

The restrictions still to account for

This is the half of the picture that gets lost when the headline reads "sanctions lifted." Every row is a separate question with a separate answer.

Measure
Status
As of
What it means for you
Named entity and individual designationsThe OFAC SDN List and equivalents
In force
Ongoing
Dealing with a designated party remains prohibited. Screen every counterparty, every time.
Export controls on controlled and dual-use goods
Eased, not removed
2025 to 2026
Licensing may still be required depending on the item and end use. Check with Commerce.
State Sponsor of Terrorism designationCarries its own restrictions independent of the sanctions programme
Verify current
Under review
In place as of late 2025 and subsequently under review. Confirm the present position directly.
UK measures
Partially eased
2025 to 2026
The UK has eased on its own timetable. Consult the UK consolidated list.
EU measures
Partially eased
2025 to 2026
Likewise the EU. Consult the EU consolidated list.
Correspondent banking accessNot a sanction, but the practical constraint that behaves like one
Constrained
Sept 2026
Legal does not mean bankable. Establish your payment route before committing.
The point of this table: every row is a separate question with a separate answer, and the wider relief does not resolve any of them on its own.

What this changes, and what it doesn't

WHAT BECAME POSSIBLE

  • Ordinary commercial dealings with non-designated Syrian counterparties
  • Activity in infrastructure, energy, services, and trade without Caesar exposure
  • Non-US firms and banks engaging without fear of secondary sanctions
  • Humanitarian and development funding flowing with far less friction
  • Banks reassessing Syria from prohibited to merely difficult
  • Diaspora investment and remittance channels reopening

WHAT DID NOT CHANGE

  • Dealing with a designated person or entity is still an offence
  • Controlled and dual-use exports may still need a licence
  • Your own jurisdiction may be more restrictive than the US
  • Banks can decline on risk appetite even where the law permits
  • Insurance and freight remain harder and dearer than the regional norm
  • Diligence obligations on source of funds and ownership still apply

Before any transaction

Not a substitute for counsel. This is the order in which the questions are usually best answered.
  1. Screen every counterparty against the current OFAC SDN List and the UK and EU consolidated lists, including beneficial owners rather than just the contracting entity.
  2. Establish your own jurisdiction's position. US relief does not bind the UK, the EU, or anyone else, and some regimes remain more restrictive.
  3. Check whether your goods or services need a licence, particularly anything with a dual-use classification or a technology component.
  4. Confirm a working payment route with your bank before signing, not after. This is where more deals have stalled than on any legal point.
  5. Do provenance diligence on assets, especially real property and anything privatised or transferred during the previous era.
  6. Take written local advice on company form, registration, and title, from counsel qualified in Syria rather than from a regional generalist.
  7. Document your diligence. The relief is recent and reviewable; a clear record of the checks you ran is worth having.
Commonly asked

Quick answers

Are sanctions on Syria over?

The comprehensive US programme was revoked and the Caesar Act repealed, so the broad country-level restrictions are gone. Named designations, export controls, and other measures remain, and the UK and EU positions are separate.

Why does the Caesar Act repeal matter separately?

Because it was a statute rather than an executive order. Only Congress could remove it, and while it stood it exposed non-US firms and banks to secondary sanctions, which is what kept most international institutions away entirely.

Could sanctions come back?

The repeal was unconditional, but the framework includes periodic presidential reporting to Congress on specified conditions, and executive measures can in principle be reintroduced. We would describe the relief as durable rather than irreversible.

My bank still says no. Is that legal?

Yes. Banks set their own risk appetite and may decline business the law permits. Correspondent banking access is currently the practical bottleneck rather than the legal position.

Sources

  1. Executive Order 14312, 30 June 2025, revoking the comprehensive Syria sanctions programme. Retrieved September 2026.
  2. US Department of State, Syria Sanctions page. Retrieved September 2026.
  3. FY2026 National Defense Authorization Act, signed 18 December 2025, repealing the Caesar Syria Civilian Protection Act of 2019, together with post-repeal certification provisions.
  4. Joint Tri-Seal Advisory on sanctions and export-control relief for Syria, Commerce, Treasury and State, November 2025.
  5. OFAC Specially Designated Nationals list. Must be checked at the time of any transaction rather than relied on from this page.
  6. UK and EU consolidated sanctions lists, for the positions of those jurisdictions.
  7. World Bank reconstruction cost estimate, approximately 216 billion dollars, as reported in 2026.
Last reviewed September 2026. This page is a summary of the public record and is not legal advice, a compliance opinion, or clearance to transact. The sanctions position on Syria has changed repeatedly since December 2024 and may have changed again since this review. Verify every point against the primary sources listed above, screen all counterparties against current designation lists at the time of the transaction, and take advice from counsel qualified in your own jurisdiction. If you believe anything on this page is wrong or out of date, please tell us and we will correct it with a dated note.