On May 23, 2025, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued Syria General License 25 (“GL 25”), effectively lifting U.S. sanctions on Syria.  This move follows President Trump’s announcement on May 13, 2025, during a trip to the Middle East, that the United States would lift sanctions on Syria following the overthrow of the Assad regime and the establishment of a transitional government led by President Ahmed al-Sharaa.

In an accompanying press release, the Treasury Department noted that sanctions relief “is intended to help rebuild Syria’s economy, financial sector, and infrastructure,” and that “it is critical to bring new investment into Syria and support the new Government of Syria.”  The Treasury Department indicated that the sanctions relief is contingent upon the new Syrian government implementing effective measures to safeguard its religious and ethnic minorities and to refrain from providing safe harbor to terrorist groups. The U.S. government will continually monitor Syria’s progress toward these goals.

Key Provisions of GL 25:

• Authorized Transactions.  GL 25 authorizes all transactions previously prohibited under the Syrian Sanctions Regulations (31 C.F.R. part 542) (the “SySR”), except for transactions involving most blocked persons.  These authorized transactions include the provision of services to people and companies in Syria, new investment in Syria, and the import of or dealing in petroleum and petroleum products from Syria.  U.S. banks are authorized to process transactions for any activities authorized by GL 25.  However, GL 25 does not unblock any property or interests in property that were blocked as of May 22, 2025. 
• Transactions with Blocked Persons.  GL 25 authorizes transactions involving certain blocked persons, as well as any entity 50 percent or more owned by such persons.  These authorized parties include the Government of Syria—led by President al-Sharaa—as well as various state-owned enterprises, financial institutions, and ministries, as identified in an Annex to GL 25.  Transactions involving blocked persons not listed in the Annex remain prohibited.  
• Russia, Iran, and North Korea.  GL 25 does not permit transactions for or on behalf of the Russian, Iranian, or North Korean governments that would otherwise fall within the scope of the general license.  In addition, GL 25 does not authorize the transfer or provision of any goods, technology, software, funds, financing, or services to or from Russia, Iran, or North Korea.  
• Compliance with Other Laws.  Notably, neither the Commerce Department’s Bureau of Industry and Security (“BIS”) nor the State Department’s Directorate of Defense Trade Controls (“DDTC”) made changes to U.S. export control regulations with respect to Syria.  Therefore, the prohibition on exports and reexports of U.S.-controlled items (including software and technology) remains in place until the U.S. export control agencies announce any relevant changes.

Concurrent with the issuance of GL 25, the State Department issued a 180-day waiver of mandatory secondary sanctions imposed under the Caesar Syria Civilian Protection Act of 2019 (the “Caesar Act”) on non-U.S. persons with respect to activity that (i) would have been prohibited by the SySR; or (ii) involves any of the blocked persons covered by GL 25.  The Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) also issued relief by authorizing U.S. financial institutions to maintain correspondent accounts in the United States for the Commercial Bank of Syria under certain conditions.

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