OFAC Syria Sanctions & Trade Restrictions in 2026
Syria’s sanctions landscape has changed more dramatically in the past two years than at any point since 1979. Following the fall of the Assad government in December 2024, the United States moved through a series of general licenses, executive orders, and finally a full congressional repeal of the Caesar Act — dismantling what was, until 2025, one of the most comprehensive sanctions regimes in the Middle East.
If your business, transaction, or banking relationship was previously affected by Syria sanctions, the rules have likely changed in your favor — but targeted restrictions still apply to specific individuals, entities, and transactions connected to Russia or Iran. Our law firm helps clients determine exactly where they stand today, resolve legacy blocked-fund issues, and obtain any remaining authorizations still required.
Syria Sanctions in 2026: What Changed
The U.S. sanctions regime against Syria has been fundamentally dismantled since the fall of the Assad government. The key milestones:
- January 2025 — OFAC issued General License 24, the first formal step toward sanctions relief following the change in government.
- May 2025 — President Trump announced his intent to lift sanctions on Syria during a visit to Saudi Arabia. OFAC issued General License 25, alongside a 180-day State Department waiver of mandatory Caesar Act sanctions, authorizing transactions supporting Syria’s recovery and reconstruction.
- June 30, 2025 — Executive Order 14312 (“Providing for the Revocation of Syria Sanctions”) revoked the six executive orders that had formed the legal foundation of the Syria sanctions program (including E.O. 13338, 13572, 13573, 13582, 13894, and 13606) and terminated the national emergency underlying them.
- November 10, 2025 — A second 180-day suspension of Caesar Act sanctions was issued, preserving an exception for transactions involving the governments of Russia or Iran, or Russian- or Iranian-origin goods, technology, software, or financing.
- December 18, 2025 — Congress fully repealed the Caesar Syria Civilian Protection Act as part of the FY2026 National Defense Authorization Act. The Caesar Act — and the threat of secondary sanctions it created for non-U.S. companies worldwide — is no longer in force.
- 2026 — OFAC renamed its Syria framework the Promoting Accountability for Assad and Regional Stabilization Sanctions Regulations (PAARSS), formally removing Syria from the category of comprehensively sanctioned jurisdictions. Syria remains designated a State Sponsor of Terrorism, a status under active review, and targeted sanctions against specific individuals and entities tied to past human rights abuses, corruption, terrorism, or ties to Russia and Iran remain in effect.
Do I Still Need an OFAC License for Syria Transactions?
With the Caesar Act repealed and E.O. 14312 having revoked the core sanctions framework, most transactions with Syria that previously required an OFAC license no longer do. However, careful review is still required if your transaction involves:
- An individual or entity still listed on the Specially Designated Nationals (SDN) List;
- Goods, technology, financing, or services of Russian or Iranian origin connected to Syria;
- A counterparty whose status has not yet been reviewed since Syria’s removal from comprehensive sanctions.
If your company was previously denied banking services, had accounts frozen, or holds a legacy OFAC license tied to Syria-related activity, we recommend a compliance review to confirm your current status before resuming or expanding operations. See our guide to OFAC Specific & General Licenses for how the licensing process still works for any remaining restricted activity.
Syria Sanctions & Caesar Act
Operating in Syria is high-risk. We advise NGOs and businesses on exemptions, licenses, and avoiding secondary sanctions.
Get OFAC AdviceThe History Behind Syria’s Sanctions
Understanding how the sanctions regime developed explains why some restrictions were lifted quickly while others — particularly the terrorism designation and SDN-listed individuals — remain in place longer.
Western sanctions against Syria date back to 1979, when the United States included the country in the list of state sponsors of terrorist organizations. Later support by Syrian authorities for groups including Hezbollah heightened international concern about Syria’s role in regional destabilization.
The 2011 civil war marked a major turning point. Mass protests and the Syrian government’s violent suppression of civilians drew international condemnation, and confirmed use of chemical weapons prohibited under the Chemical Weapons Convention led to additional restrictive measures targeting property and weapons-related technology.
Executive Order 13338 (2004) was the first significant restrictive measure, blocking assets and prohibiting transactions with several Syrian organizations. Executive Orders 13572, 13573, and 13582 (2011 onward) expanded the list of sanctioned individuals and companies, restricted the oil industry, and prohibited import/export of certain goods. The Caesar Syria Civilian Protection Act (2020) then introduced secondary sanctions — extending U.S. sanctions risk to foreign companies worldwide that did business with the Syrian government, regardless of any direct U.S. connection.
All of these executive orders were formally revoked by E.O. 14312 in June 2025, and the Caesar Act itself was repealed in December 2025 — closing this chapter of the sanctions regime, though the underlying human rights and counterterrorism concerns that motivated it remain part of ongoing U.S. policy toward Syria’s transitional government.
Sanctions After the Turkey–Syria Earthquake (Historical Context)
In February 2023, a massive earthquake struck Turkey and Syria, killing tens of thousands. In response, OFAC issued a time-limited general license authorizing certain humanitarian financial transactions and the delivery of relief goods, and several previously blocked financial institutions were permitted to process disaster-relief transfers. This was an early precedent for the broader humanitarian carve-outs that later evolved into the general licenses issued during Syria’s 2025 political transition.
What Restrictions Remain Today
Even after the Caesar Act repeal and E.O. 14312, some restrictions persist:
State Sponsor of Terrorism Designation
Syria remains listed as a State Sponsor of Terrorism. This status carries independent legal and financial restrictions — including limits on defense exports, foreign assistance, and certain financial transactions — separate from the sanctions program that was dismantled in 2025. Removal of this designation is reportedly under active review but had not been finalized as of early 2026.
Targeted (SDN) Sanctions
Individuals and entities tied to past human rights abuses, corruption, or ongoing ties to Russia or Iran remain subject to asset freezes and transaction bans under the SDN List, even though the comprehensive country-wide program has ended. Any counterparty due diligence should include an updated SDN screening — see our OFAC SDN List Removal page if you believe a listing no longer reflects current circumstances.
Russia/Iran-Linked Transactions
The November 2025 Caesar Act suspension explicitly preserved sanctions exposure for transactions involving Russian- or Iranian-origin goods, technology, or financing connected to Syria. This carve-out survived the full repeal in practice for any residual designations tied to those two countries, so companies with supply chains touching Syria, Russia, or Iran should treat this as an ongoing compliance risk.
Cultural Heritage Protections
Restrictions on the illegal export and sale of Syrian cultural heritage items — artifacts and works of art — remain enforced independently of the broader sanctions program, backed by international mechanisms including UNESCO controls.
Syria General Licenses — Historical and Current
General licenses have played a central role throughout Syria’s sanctions history, both under the old comprehensive regime and during the 2025 transition:
- General License 24 (January 2025) — the first relief measure following the change in government.
- General License 25 (May 2025) — broadly authorized transactions supporting Syria’s recovery, reconstruction, and engagement with the transitional government, alongside the initial Caesar Act waiver.
- Earlier humanitarian general licenses (issued under the pre-2025 regime) authorized food, medicine, and medical equipment delivery, access to non-military communication technology, and remote educational programs — these categories remain broadly relevant as a model for any future country-specific general licenses, and portions may still apply to residual restricted activity.
If your planned activity isn’t clearly covered by an existing general license — for example, if it involves an SDN-listed party or Russia/Iran-linked elements — a specific license from OFAC is still required. Our OFAC Specific & General License page walks through the application process, required documentation, and typical timelines.
Syria Sanctions Lawyers
Syria’s transition from a comprehensively sanctioned jurisdiction to a more narrowly targeted sanctions posture is one of the fastest regulatory shifts in OFAC’s history, and many companies that stopped doing business with Syria years ago have not yet reassessed their position under the current rules. Our team helps clients:
- Confirm current compliance status — determine whether previously restricted activity is now permitted, and whether any legacy license or blocked-fund issue needs to be resolved.
- Screen counterparties — verify that individuals and entities involved in a transaction are not among the SDN-listed parties still subject to restrictions.
- Resolve blocked or frozen funds — if a bank froze a Syria-related transaction under the old regime and hasn’t released it, we can help demonstrate that the underlying activity is no longer restricted. See our OFAC Release of Blocked Funds page.
- Navigate Russia/Iran-linked exposure — assess supply chains and counterparties for residual sanctions risk tied to Syria’s remaining restrictions.
- Build or update compliance programs — for companies re-entering the Syrian market, we help design due diligence procedures suited to the new regulatory environment. See our Development of AML/CFT Systems and Strategic Due Diligence page.
- Obtain any remaining required licenses — for the narrower set of activities still requiring OFAC authorization.
Contact our OFAC sanctions attorneys to get an accurate, current assessment of your Syria-related compliance obligations — the rules have changed substantially, and relying on outdated guidance is itself a risk.
FAQ
How does the Caesar Act affect sanctions against Syria?
As of December 2025, it no longer does — Congress fully repealed the Caesar Syria Civilian Protection Act as part of the FY2026 National Defense Authorization Act. Before its repeal, the Act had broadened U.S. authority to impose secondary sanctions on any foreign person providing significant financial, material, or technological support to the Syrian government. That risk no longer applies, though targeted sanctions against specific individuals and entities remain in place.
Are there OFAC sanctions exceptions for humanitarian aid to Syria?
Yes — historically, OFAC authorized humanitarian activities including food, medicine, and medical supplies through general licenses, and NGOs could often operate without a specific license if their activities complied with those terms. Since 2025, humanitarian and reconstruction-related transactions are even more broadly permitted under General License 25 and the revocation of the underlying sanctions framework, though transactions involving SDN-listed parties still require careful screening.
What should I do if my bank blocked a transfer linked to Syria?
Given how significantly the sanctions landscape has changed since 2025, many transactions blocked under the old comprehensive regime may now be permissible. We recommend a legal review to confirm the transaction’s current status and, if appropriate, to help present the case to your bank or file directly with OFAC for release of the funds. See our OFAC Release of Blocked Funds page for the process.
Is Syria still a comprehensively sanctioned country?
No. Following Executive Order 14312 (June 2025) and OFAC’s rebranding of its Syria framework as the Promoting Accountability for Assad and Regional Stabilization Sanctions Regulations, Syria is no longer classified as a comprehensively sanctioned jurisdiction. Targeted sanctions against specific individuals, entities, and Russia/Iran-linked transactions remain in effect, and Syria still carries a State Sponsor of Terrorism designation.
