On January 6, 2025, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued Syria General License (GL) 24 to expand authorizations for activities and transactions in Syria following the events of December 8, 2024, and the removal of Bashar al-Assad from power.  The intent of the GL is to  ensure that U.S. sanctions do not impede activities to meet basic human needs, including the provision of public services or humanitarian assistance. The GL will be effective for six months – until July 7, 2025 – as the United States monitors the situation in Syria.

In implementing  Syria GL 24, OFAC notes that, “Given the extraordinary circumstances, and to support the Syrian people as they build a more hopeful, secure, and peaceful future, … [OFAC] is issuing GL 24 to help ensure that sanctions do not hinder services and continuity of governance functions across Syria, including the provision of electricity, energy, water, and sanitation.”  OFAC acknowledges that this GL may overlap with existing authorizations allowing for the provision of humanitarian support and aid in Syria, but will also provide clarity on certain authorized government-related services and transactions.  Syria GL 24 authorizes:

  • transactions with governing institutions in Syria following December 8, 2024;
  • transactions in support of the sale, supply, storage, or donation of energy, including petroleum, petroleum products, natural gas, and electricity, to or within Syria; and
  • transactions that are ordinarily incident and necessary to processing the transfer of noncommercial, personal remittances to Syria, including through the Central Bank of Syria.

OFAC FAQ 1207 provides more specific guidance as to what transactions are generally authorized and those that are not authorized.

The term “Syrian governing institutions” includes departments, agencies, and government-run public service providers (including public hospitals, schools, and utilities) at the federal, regional, or local level in Syria following December 8, 2024, including entities involved with Hay’at Tahrir al Sham (HTS) across all geographic areas of Syria.  It does not include or authorize transactions involving military or intelligence entities or persons.

It must be noted that this GL 24 does not unblock the property or interest in property of any blocked person under any of our sanctions programs, including Assad and his associates, the Government of Syria, Central Bank of Syria, or HTS; nor does it authorize any financial transfers to any blocked person other than for the purpose of effecting certain authorized payments to governing institutions or associated service providers in Syria. Further, this GL does not remove the restrictions placed on Syria under the State Sponsor of Terrorism (SST) designation.  Certain other transactions under this general license remain unauthorized and therefore requires close analysis before self-executing any transactions pursuant to Syria GL 24.