Is Syria Open for Business?

US, EU, and UK Sanctions Relief Paves the Way for New Investment Opportunities

In the months after the fall of the Assad government in December 2024, the US, EU, and UK governments have lifted most sanctions on Syria.  The dramatic changes to these sanctions programs present commercial and investment opportunities in Syria that have effectively been closed off to international business for the past 14 years.

This is the first installation in a series, in which we explore the recent changes to the sanctions landscape relating to Syria, and discuss the risks and challenges investors should consider when investing in Syria.

The United States has revoked US primary sanctions on Syria and dismantled its comprehensive Syria sanctions program by rescinding the Syrian Sanctions Regulations (the SySR).  The Trump Administration has issued a temporary waiver of secondary sanctions under the Caesar Act, which must be renewed every 180 days.  To make the waiver permanent, the Trump Administration has directed the US State Department to suspend some or all of the mandatory secondary sanctions under the Caesar Act, with a full repeal of the law potentially on the way in Congress.  The US Commerce Department has notified its intention to relax export controls on Syria in the “fairly near future”, US export controls under the Export Administration Regulations and International Traffic in Arms Regulations remain in effect.

The EU and UK have also removed most of their sanctions on Syria.  The EU lifted key asset freeze sanctions as well as the majority of its product and sectoral restrictions on Syria, including those targeting Syria’s banking, energy, and trade sectors.  The UK also lifted asset freezes and trade sanctions targeting the Syrian government and various sectors of the Syrian economy.  The EU and UK have retained certain sanctions and (in the case of the UK) counter-terrorism proscriptions in respect of individuals and entities in Syria. 

These developments have significantly altered sanctions and trade policy on Syria, and these changes present an opportunity for companies to do business related to Syria.  Syria is likely to remain a jurisdiction with meaningful compliance risks—including under certain sanctions, export controls, anti-bribery and corruption laws, and anti-money laundering laws.  However, the international community no longer faces blanket sanctions restrictions and is now able to explore opportunities to conduct business in previously restricted sectors of Syria’s economy and to engage with formerly blocked Syrian financial institutions. 

United States

Since the overthrow of Bashar al-Assad’s regime, the United States has relaxed sanctions on Syria.  These changes are intended “to encourage new investment into Syria”.  

• Termination of the Syria sanctions program: On June 30 and July 7, 2025, President Trump issued Executive Order 14312 (EO 14312), terminating the national emergency underlying the SySR and striking the SySR from the Code of Federal Regulations. 
• Delisting of Syrian SDNs: The US Treasury Department’s Office of Foreign Assets Control (OFAC) removed 518 individuals and entities from the Specially Designated Nationals and Blocked Persons List (SDN List). Hay’at Tahrir al-Sham (HTS), Syria’s new ruling party, and its leader, Abu Muhammad al-Jawlani (a.k.a. Ahmed al-Sharaa) currently remain on the SDN List.
• Authorizing previously restricted dealings: The United States dropped its prohibition on providing financial services to Syria, processing Syria-related payments, and conducting transactions with Syrian banks and the Syrian government.  OFAC also issued a general license (GL25) authorizing transactions related to Syria, the Syrian government, and SDNs listed in the Annex to GL25.  Accordingly, US financial institutions are now authorized to transact with Syrian banks and establish correspondent relationships. 
• Revoking terrorism designations: The US State Department removed the Foreign Terrorist Organisation designation of HTS and al-Nusrah Front, effective July 8, 2025. As noted above, HTS and Ahmed al-Sharaa remain on the SDN List, pending a review of these designations as directed by EO 14312.  Additionally, EO 14312 instructs the US State Department to assess whether to remove Syria’s designation as a State Sponsor of Terrorism, which is a prerequisite for lifting certain restrictions. 
• Waiver of secondary sanctions under the Caesar Act: The Trump Administration has issued temporary waivers of secondary sanctions under the Caesar Act, which must be renewed every 180 days.  EO 14312 directs the US State Department to examine whether to suspend some or all the mandatory secondary sanctions under the Caesar Act and report findings to Congress within 30 days of its determination.  Congress may repeal the Caesar Act, which could lead to more permanent secondary sanctions relief.
• Introducing new sanctions program targeting those affiliated with the Assad regime: The United States has retained limited sanctions involving Syria under a new program called Promoting Accountability for Assad and Regional Stabilization Sanctions, which targets, among other things, persons linked to the previous Syrian government. 
• Keeping in place US export controls (for now): US export controls on Syria imposed by the US Department of Commerce’s Bureau of Industry and Security (BIS) are still intact.  The US government, however, waived several export control provisions imposed under the Syria Accountability and Lebanese Sovereignty Restoration Act and the Chemical and Biological Weapons Control and Warfare Elimination Act, including those affecting US foreign assistance, export financing, and sensitive technology transfers.  This allows BIS to modify or rescind the Syrian trade embargo. 

European Union

The EU has lifted most of its sanctions on Syria, including those targeting the energy, banking, transport, and insurance sectors.  Notably, major financial institutions such as the Central Bank of Syria, Commercial Bank of Syria, and Real Estate Bank have been delisted from the EU’s sanctions list, enabling EU banks to resume interactions with Syrian financial institutions and facilitating transactions that were previously prohibited due to the involvement of sanctioned Syrian banks. Similarly, the removal of asset freezes on major energy companies—like the General Petroleum Corporation, Syrian Petroleum Company, and Al Furat Petroleum Company—paves the way for sanctions-compliant investment and business activities in the petroleum sector.

Furthermore, product restrictions have been significantly scaled back, now permitting the import and export of crude oil, jet fuel, petroleum products and certain luxury goods. Sectoral restrictions have likewise been eased, allowing the participation in public infrastructure projects, the sale and purchase of Syrian public bonds, and the provision of insurance and financial services to Syrian state entities.  Syrian aircraft may also resume flying in EU airspace.  

Despite the extensive easing, the EU maintains an arms embargo, export restrictions on repression-related goods, and asset freezes on over 350 individuals and entities linked to the Assad regime, as well as al-Sharaa and HTS. Accordingly, it is advisable for investors to monitor EU regulatory developments and exercise appropriate due diligence, especially when dealing with former members of HTS or entities affiliated with the former Assad regime.

United Kingdom

The UK removed most of its Syria sanctions, dropping restrictions on energy, banking, and transport sectors and delisting several state entities.  The UK, however, retains prohibitions on dealings in luxury goods, gold, diamonds, and security-sensitive items.  Additionally, UK asset freezes still target over 300 individuals and entities, and bond restrictions tied to the Assad regime continue.  UK officials have indicated that further reforms will depend on continued progress by Syria’s new government. 

HTS remains a Proscribed Terrorist Organisation under UK counter-terrorism laws, such that it is prohibited to make funds available to HTS or for its benefit.  Given that a number of officials in the Syrian interim government, including its Interim President, were prominent members of HTS, the distinction between the new government and HTS requires careful consideration as matters continue to develop.

Conclusion: Business and Investment Opportunities in Syria

The removal of many US, EU, and UK sanctions on Syria paves the way for new investment and commercial opportunities relating to Syria.  Investors may now cautiously reengage with a country that had been under comprehensive sanctions for more than a decade, subject to the remaining targeted restrictions.  Additionally, the delisting of the Central Bank of Syria and other key institutions provides investors access to Syria’s local financial systems, enabling capital flows and correspondent banking relationships. 

The trend remains toward further relaxation of restrictions on business with Syria, subject to the next steps of the new Syrian government and the progress of its ongoing relations with the international community.  Companies considering business and investment in Syria, however, should beware of the US, EU, and UK restrictions that are still in effect and which will require careful consideration as part of any plan to engage in new opportunities relating to Syria.