After the fall of the former regime of Bashar al-Assad in Syria, the Presidential Administration has taken steps to formally dismantle the U.S.’s two-decade-long comprehensive trade restrictions on Syria. These steps began with the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issuing a General License in May 2025 authorizing most transactions otherwise prohibited by the trade and economic sanctions administered by OFAC. On June 30, 2025, effective July 1, 2025, the Administration issued an Executive Order (EO) that formally revoked these sanctions and authorized both the U.S. Department of State and the U.S. Department of Commerce to take steps to implement the order.
This shift marks the most significant realignment of U.S. policy toward Syria since the publication of a 2004 EO prohibiting the export of most goods to Syria and the subsequent issuance of the Syrian Sanctions Regulations in 2005. While targeted sanctions remain in place on former Syrian president Bashar al-Assad, his associates, and other designated actors, the broad country-wide restrictions on trade, investment, and exports are now in the process of being rescinded. At this point, however, the export controls administered by the Department of Commerce’s Bureau of Industry and Security (BIS) currently remain in effect, prohibiting the export of all items subject to the Export Administration Regulations (EAR) other than food and medicine.
Lifting Sanctions
On May 13, 2025, after the fall of the former Assad regime, President Trump announced his intent to lift most sanctions on Syria, signaling a dramatic shift in U.S. policy. Just 10 days later, on May 23, 2025, OFAC issued Syria General License 25 (GL 25), effectively suspending most prohibitions under the Syrian Sanctions Regulations at 31 C.F.R. § 542. Also on May 23, 2025, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an Exception to its rule imposing special measures against the Commercial Bank of Syria, allowing certain U.S. financial institutions to open and maintain correspondent accounts with the bank under certain conditions.1
Simultaneously, the Department of State issued a 180-day Waiver under the Caesar Syria Civilian Protection Act of 2019 (Caesar Act). The Caesar Act imposes secondary sanctions on foreign persons who knowingly engage in certain significant transactions with the former Syrian government or support its military, reconstruction, or energy sectors; this waiver suspends the application of certain sanctions on specified transactions involving the former Syrian government and SDNs listed in the GL 25 Annex. It does not extend to transactions involving SDNs not listed in the GL 25 Annex, dealings involving Russia, Iran, North Korea, or transfers of restricted goods, technology, or services involving Russia, Iran, or North Korea.
These measures set the stage for a broader policy shift. On June 30, 2025, the Administration issued a new Executive Order formally removing most sanctions on Syria,2 effective July 1, 2025, while maintaining sanctions on former Syrian president Bashar al-Assad and certain other destabilizing regional actors involved in activities such as narcotics trafficking and human rights abuses. The EO directs the Secretary of State to evaluate whether sanctions imposed under the Caesar Act may be suspended, in whole or in part, upon the satisfaction of specified criteria.
Although the Executive Order directs the easing of export controls on Syria, BIS has not yet formally lifted restrictions under the EAR. At present, only food or medicine designated as EAR99 is permitted for export or reexport to Syria without a license.3 Forthcoming BIS guidance is expected to rescind export licensing requirements on lower-controlled items destined for Syria, including the presumption of denial for export or reexport of many U.S.-origin items subject to the EAR. Until such changes are published in the Federal Register, companies must continue to comply with BIS regulations, and most exports or reexports to Syria remain subject to licensing.
Companies considering entry into the Syrian market should closely monitor for imminent BIS updates and be prepared to adjust compliance procedures as U.S. export control policy is brought into alignment with the Administration’s EO.
Key Takeaways
Monitor for Rescission of U.S. Export Controls
Although life sciences and technology firms may now pursue limited engagements with Syrian institutions and venture and private equity firms can also consider investments in Syrian start-ups, we advise that these undertakings proceed with caution, as export control restrictions remain in place.
As discussed above, while OFAC has taken swift action to enact the U.S. policy shift toward Syria, BIS has not yet implemented corresponding changes to the EAR. Companies exporting any items and technology subject to the EAR (other than food and medicine), including electronics, downloadable software, and virtually all other items, must continue to comply with existing BIS licensing requirements until the regulations are modified. Even after the expected rescission, companies should remain alert to ongoing licensing obligations and end-use or end-user risks under the EAR.
Reassess Compliance Protocols, Keeping in Mind That Contractual Obligations and SDN Restrictions Remain
Despite the lift of U.S. comprehensive sanctions on Syria, allowing U.S. persons to engage in a broad range of commercial, financial, and investment transactions, significant restrictions on sanctioned persons and entities remain. In addition, many companies have made representations to financial institutions and third parties about not doing business in Syria. Any such contractual representations would need to be reviewed to determine if such business could be undertaken even if lawful.
Companies should exercise heightened diligence around affiliations with the Syrian military, intelligence services, or entities linked to other sanctioned jurisdictions (e.g., Iran or Russia) and continue to screen counterparties and verify beneficial ownership to ensure compliance with OFAC’s SDN regulations. Software companies and digital platforms should review whether geo-IP blocking controls for Syrian IP addresses can be removed in light of current authorizations. As with any change to export controls or sanctions, opportunity to revisit customer screening and export classification procedures across product lines to ensure that adequate and up-to-date measures remain in place.
For more information or assistance with reviewing compliance policies and procedures related to Syria, please contact Josephine Aiello LeBeau, Anne Seymour, Kara Millard, or any member of the Export Control and Sanctions practice at Wilson Sonsini Goodrich & Rosati.
[1]This relief does not alter institutions’ due diligence obligations under Section 312 of the USA PATRIOT Act and 31 C.F.R. § 1010.610.
[2]See more description under the White House Fact Sheet.
[3]Robust BIS Guidance on Syria also notes several categories of items that it currently reviews on a case-by-case basis, rather than the presumption of denial.
