On June 30, President Trump signed Executive Order 14312, "Providing for the Revocation of Syria Sanctions" (EO), which formally terminates many U.S. sanctions on Syria. Public reports indicate that the European Union has also lifted nearly all sanctions on Syria.
While this is a pivotal step toward helping Syria navigate a path to re-engaging with U.S. markets and businesses, most U.S. export restrictions on the country remain in place.
Sanctions Relief Intended to Help Syrian Individuals and Businesses Without Benefitting Past Leaders
The EO follows the May 23 issuance of Syria General License 25 by the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) to authorize transactions involving the interim Syrian government, its central bank, and certain other parties and the simultaneous 180-day waiver issued by the U.S. Department of State of secondary sanctions under the Caesar Syria Civilian Protection Act (Caesar Act). OFAC is the primary U.S. government agency charged with administering and enforcing U.S. sanctions; the State Department also plays an important role in U.S. sanctions.
We wrote previously about the actions of May 2025 here.
The EO lifts the national emergency declared in Executive Order 13338, "Blocking Property of Certain Persons and Prohibiting the Export of Certain Goods to Syria," issued in 2004, and revokes five other previous executive orders related to Syria.
In particular, pursuant to the EO, OFAC de-listed over 500 prohibited parties, unblocking all property and interests in property of such parties that are in the United States or in possession or control of U.S. persons. Furthermore, OFAC announced that it would remove the Syria Sanctions Regulations from the Code of Federal Regulations.
Notably, OFAC will maintain certain sanctions through the new Promoting Accountability for Assad and Regional Stabilization Sanctions (PAARSS) program. The PAARSS program targets the former regime of Bashar al-Assad as well as individuals and entities designated for involvement in other malign activity, such as drug trafficking, chemical weapons or proliferation-related activities, terrorism, and human rights abuses.
Executive Order Instructs Secretary of State to Take Additional Action Related to Export Controls and Other Restrictions
In addition to the termination of sanctions described above, the EO tasks the Secretary of State with several other actions, including:
- Reviewing the designations of current Syria president Ahmed al-Sharaa as a Specially Designated Global Terrorist and the organization Hay'at Tahrir al-Sham (HTS) as a Foreign Terrorist Organization (FTO).
- Evaluating the potential suspension of secondary sanctions under the Caesar Act, subject to certain conditions.
- Reviewing whether Syria can shed its label as a State Sponsor of Terrorism.
In a further show of how quickly the administration is moving on this front, the Department of State revoked the FTO designation of HTS, effective July 8. The revocation "followed the announced dissolution of HTS and the Syrian government's commitment to combat terrorism in all its forms." Further sanctions relief could also follow depending on the outcome of the State Department's review related to the Caesar Act and the State Sponsor of Terrorism designation.
In addition, the EO waives certain provisions of the Syria Accountability and Lebanese Sovereignty Restoration Act of 2003 and Chemical and Biological Weapons Control and Warfare Elimination Act of 1991. These waivers are significant because both statutes require the imposition of export controls on Syria; the waivers mean that, subject to certain conditions being met, export controls on Syria can be eased. Correspondingly, it is expected that the U.S. Department of Commerce, which maintains primary jurisdiction over controls on exports and re-exports of commercial items, will relax or remove many of these controls.
Importantly, however, the Commerce Department has not to date issued guidance or announced when or which controls may be eased. As a result, a license is still required for the export or re-export of almost any U.S. item to Syria other than food and medicine.
Brad Smith, the Treasury Department's Acting Undersecretary for Terrorism and Financial Intelligence, stated the order is meant to "end the country's isolation from the international financial system, setting the stage for global commerce and galvanizing investments from its neighbors in the region, as well as from the United States."
While commercial opportunities with Syria are likely to expand, because of ongoing export and other restrictions, businesses must proceed with caution. Appropriate compliance measures, such as conducting careful know your customer (KYC) and other due diligence and ensuring full understanding of export classifications and license requirements, are essential.
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