Syria Sanctions Relief

On January 6, 2025, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued Syria General License (GL) 24, providing sanctions relief for the Syrian people after the fall of former Syrian President Bashar al-Assad on December 8, 2024.

Treasury described the GL as a “new path forward” for the Syrian people, helping them ensure a peaceful future, while clearing the way for the unhindered provision of electricity, energy, water, and sanitation, as well as humanitarian aid. The GL also builds on existing authorizations, including those that support the activities of nongovernmental organizations, humanitarian groups, and international organizations.

What’s Changed?

The GL authorizes certain transactions associated with energy, public services, and personal remittances through July 7, 2025. Transactions that involve transfers of noncommercial, personal remittances to Syria are also allowed, including through the Syrian Central Bank.

With respect to energy, the GL authorizes transactions in support of the sale, supply, storage, or donation of energy, including petroleum, petroleum products, natural gas, and electricity, to or within Syria, such as the donation of gasoline to Syrian refineries and power plants, according to OFAC.

The GL also allows transactions with certain governing institutions in Syria, even if a designated individual has a leadership role in that governing institution. These authorizations include:

• Providing services to, or paying for services received from, Syrian governing institutions, such as the Ministry of Health, the Ministry of Education, or the Ministry of Water Resources;
• Payment of taxes, fees, or import duties to Syrian governing institutions;
• Purchase or receipt of permits, licenses, public utility services, or other public services;
• Payment of salaries or wages to employees of governing institutions in Syria, provided such employees are not designated on OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List); and
• Negotiating contracts or other agreements with Syrian governing institutions.

However, OFAC notes that transactions with Syria’s intelligence or military entities are not authorized. In addition, any transaction for or on behalf of the Iranian or Russian government is prohibited, including transactions related to the provision of Russian- or Iranian-origin goods, technology, software, funds, financing, or services. New investment in Syria and financial transfers to any person blocked pursuant to the Syrian Sanctions Regulations, the Global Terrorism Sanctions Regulations, or the Foreign Terrorist Organizations Sanctions Regulations are also prohibited.

A Gradual Approach

The Assad regime collapsed during a major offensive by opposition forces, led by Hay’at Tahrir al-Sham (HTS). The group, according to the Office of the Director of National Intelligence’s Counterterrorism Guide, is a coalition of Sunni Islamist insurgent groups based in Syria. HTS evolved from Jabhat al-Nusrah, (aka Nusrah Front)—al-Qa‘ida’s former branch in Syria. The group was designated as a foreign terrorist organization (FTO) in May 2018. The group’s leader, Abu Muhammad al-Jawlani has been the leader of HTS from the group’s inception in 2017. He was designated pursuant to Executive Order (EO 13224) on May 16, 2013. He severed ties with al-Qa‘ida in 2016.

Jawlani since the fall of Assad has been using his real name, Ahmed al-Sharaa, in official communications. However, he and HTS remain sanctioned by the UN, United States, UK, and other nations.

Each country and organization that has imposed sanctions on Syria is taking a different path for removing sanctions.

• The United States has not lifted sanctions on Syria, choosing instead a gradual approach, and authorizing certain transactions to help the Syrian people for six months. The U.S. Justice Department has also dropped a $10 million bounty offered for the capture of al-Sharaa.
• France confirmed recently that EU sanctions in Syria that obstruct humanitarian aid and hinder the country’s recovery would be quickly lifted. Recent media reporting indicates that some sanctions against Syria could be lifted as early as this month, when EU foreign ministers meet in Brussels.
• UK Foreign Secretary David Lammy in December confirmed that although HTS remains sanctioned, the country has had diplomatic contact with the new Syrian regime.

The United States, the EU, and others almost certainly hope that the fall of the Assad regime paves the way for a free and democratic Syria that will foster enough trust in the new government to start removing sanctions. They likely will seek assurances that the new government will exclude Iran and Russia from Syria, deny terrorist groups access to the country, and encourage democratic institutions and elections to thrive.

• Al-Sharaa told Al Arabiya TV in late December that elections in Syria could take as long as four years, with rewriting the country’s constitution possibly taking two or three years. UN Security Council Resolution 2254 in 2015 outlined a roadmap for a political transition in Syria that included drafting a new constitution and holding UN-supervised elections, indicating the significant amount of work to be done in the transition.
• Al-Sharaa also plans to announce the dissolution of HTS, although no date has been specified.
• A spokesman for Syria’s new transitional government publicly promised in December that the new Syria will be “inclusive and open to the world,” according to the Associated Press, which would almost certainly help convince global jurisdictions to remove at least some sanctions.

What Remains the Same?

Despite Al-Sharaa’s promises, the international community has not indicated plans to remove him from its terrorism lists, and the U.S. State Sponsor of Terrorism designation against Syria remains.

The recent GL 24 does not authorize financial transfers to blocked persons other than for the purpose of effecting certain payments to governing institutions or for the purchase or receipt of permits, licenses, public utility services, or other public services in Syria, and importing Syrian oil into the United States is still prohibited.

Key Considerations

Financial institutions and other firms that engage in activities authorized by GL 24 must be cautious, ensuring that their transactions do not involve designated terrorists. Although certain transactions with Syria’s transitional government are authorized, direct transfers to those blocked by U.S. terrorism and Syria sanctions authorities are still prohibited.

Although transactions that involve transfers of noncommercial, personal remittances to Syria—including through the Central Bank of Syria—are authorized, individuals and entities involved in these transfers should consider careful screening of the recipients to ensure they are not designated pursuant to U.S. terrorism authorities and do not involve Syria’s military or intelligence agencies. OFAC has specifically noted that “Nothing in this general license relieves any person from compliance with any other Federal laws or requirements of other Federal agencies, including the International Traffic in Arms Regulations (ITAR) administered by the Department of State and the Export Administration Regulations (EAR) administered by the Department of Commerce.”

And because the GL initially has been approved for six months, it can be allowed to expire should Syria backslide into a haven for terrorist organizations, criminal groups, or violators of human rights. Therefore, organizations that take advantage of nascent opportunities to transact in Syria should ensure that they protect themselves should sanctions relief be revoked by closely monitoring regulatory changes and geopolitical developments in the region, documenting details about their transactions in Syria, including dates of transactions to ensure they are not violating sanctions, and performing enhanced due diligence on counterparties involved in these transactions.