Relief in Syria sanctions – a brief summary of key updates from US, EU, UK, and Norway

Kaja Kallas, High Representative for Foreign Affairs and Security Policy, stated that "[t]his decision is simply 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."

Norwegian authorities have also announced support for lifting sanctions on Syria. In a statement 14 May 2025, Foreign Minister Espen Barth Eide expressed that "I welcome President Trump’s announcement that sanctions on Syria will be lifted. Norway has argued for the same regarding European sanctions. The government of President Al Sharaa must get the opportunity to prove that they can unite Syria. We remain a vigilant, but constructive friend." The measures have, however, yet to be formally relieved.

The suspension by EU, UK and US of several sanctions against Syria allows operators to initiate activities in or with Syria that previously have been subject to strict restrictions. Where companies are considering extending its business to Syria, it is recommended that any exposure to remaining sanctions measures are carefully considered, as well as to the broader corporate compliance laws and export controls. It is also important to be aware that relevant sanctions frameworks still remain in place and that authorities are relying the suspension on continuous monitoring, with a possibility of reversing suspensions on short notice. 

US updates

By the implementation of the Syria General License (GL) 25, the Department of Treasury's Office of Foreign Assets Control (OFAC) is authorising all transactions which would otherwise be prohibited by the Syrian Sanctions Regulations (31 CFR Part 542), effectively enabling new investments and business engagements in Syria. 

The following activities have now been authorised: 

• Provision of services to individuals and entities in Syria;
• Investments in Syria;
• Importing or dealing with petroleum products from Syria;
• Transactions with the new Government of Syria; and
• Transactions involving certain blocked persons, as listed in the Annex to GL 25.

Concerning the extraterritorial effect of the US sanctions against Syria, OFAC has clarified that non-US persons would not risk exposure under US sanctions for engaging in activities that would be authorised for a US person pursuant to GL 25. This is supported by the authorisation in GL 25 for US banks to process payments related to authorised activities, and by the 180-days waiver issued pursuant to the Caesar Syria Civilian Protection Act of 2019, providing that US secondary sanctions will not be issued for engagements covered by GL 25. 

It is, however, worth noting that the GL 25 does not authorise transactions with entities or individuals subject to US blocking provisions, apart from those expressly listed in the Annex of the GL. Additionally, it does not unblock property or interest in property which has been blocked prior to 22 May 2025 or allow for transactions benefiting Russia, Iran or North Korea.

No changes have been made to the US export control regulations, including to the International Traffic in Arms Regulations or the Export Administration Regulations. 

EU updates

On the basis of a political decision announced 20 May 2025, the EU has adopted acts lifting all economic restrictive measures against Syria. Changes include the delisting of 24 entities from the EU asset freeze list, mainly including banks and entities operating in key sectors of the Syrian economy, hereunder the Central Bank of Syria and companies engaged in the oil industry of Syria. 

The EU sanctions against Syria have from the outset been of a far more limited scope than those imposed by the US, and the decision taken by the EU to lift the economic measures against Syria will therefore in practice be of less significance. 

All measures aimed towards the Al-Assad regime and at safeguarding the security of the Syrian people, as well as existing arms embargo and export restrictions on equipment and technology that could be utilized for internal repression in Syria, will remain unchanged. The EU Council has also introduces new restrictions under the EU Global Human Rights Sanctions Regime, targeting actors engaged in human rights violations in Syria.

UK updates

Effective from 25 April 2025, the UK government implemented an amending regulation partially suspending several measures of the Syria (Sanctions) (EU Exit) Regulations 2019. Changes include lifting of the sectorial sanctions targeting the energy and transport sectors of Syria, and restrictions on engagements with financial and banking institutions in Syria. 

The UK still uphold trade restrictions on specific goods and technologies, amongst other things those that can be used for military-, weapons production-, interception and monitoring- or internal repression purposes, as well as gold, metals and diamonds, and luxury goods. Export restrictions and sanctions targeting the Al-Assad regime still remain in place.

In February, the UK also issued the OFSI General Licence INT/2025/5810196, allowing under certain conditions for activities necessary to provide humanitarian assistance, other activities that support basic human needs and facilitate the timely provision of those activities in Syria. The GL remains effective.