On June 30, 2025, President Donald Trump issued an Executive Order (EO) that removes sanctions on Syria, provides for the issuance of waivers that will permit the relaxation of export controls and other restrictions on Syria, and otherwise seeks to support “the positive actions” taken by the new Syrian government under President Ahmed al-Sharaa. The EO does not provide relief to certain officials and persons of the former regime of Bashar al-Assad, ISIS or other terrorist organizations, human rights abusers, those linked to chemical weapons or proliferation-related activities, or other persons that threaten the peace, security, or stability of the United States, Syria, and its neighbors.
The below offers an overview and summary of the numerous actions taken under the EO. Note, however, certain sanctions and controls prohibiting exports of U.S.-origin products remain in place as they were mandatorily implemented under legal statutes. The Secretary of State will be required to submit to the appropriate Congressional committees reports and certifications required by two Acts (noted below) prior to the actual implementation of any relaxation of covered sanctions or export controls.
As such, a close review of the June 30, 2025 EO is necessary to ensure whether a U.S. company or person can now fully engage in activities in Syria and/or with Syrian entities or persons.
Revoking OFAC Syria Sanctions but Maintaining Designations on Bashar al-Assad and His Associates
Effective July 1, 2025, the EO terminates the national emergency declared by the United States regarding Syria and revokes six past EOs that implemented sanctions and blocked property of various persons in Syria and senior officials in the Government of Syria.
In revoking the numerous EOs the Department of the Treasury’s Office of Foreign Assets Control (OFAC) has concurrently removed 518 individuals and entities from the Specially Designated Nationals (SDN) List sanctioned under the Syria sanctions program, thus “lifting sanctions on such individuals and entities critical to Syria’s development, the operation of its government, and the rebuilding of the country’s social fabric.” The list of persons and entities removed from the SDN List can be found here.
As a result of President Trump’s June 30 EO, OFAC will also remove the Syrian Sanctions Regulations, 31 C.F.R. part 542 from the Code of Federal Regulations following the July 1, 2025 revocation.
However, the scope of sanctions on certain persons impacted by EO 13894 (October 14, 2019, providing for menu-based sanctions including travel restrictions to the United States and isolation from the United States’ financial system for foreign persons who engage in or finance the obstruction, prevention, or disruption of a ceasefire or political solution to the conflict in Syria) and EO 14142 (January 15, 2025) have been amended in order to continue “to ensure meaningful accountability for perpetrators of war crimes, human rights violations and abuses, and the proliferation of narcotics trafficking networks in and in relation to Syria during the former regime of Bashar al-Assad and by those associated with it.”
As such, OFAC designated 139 individuals and entities pursuant to EO 13894 and placed them on the SDN List. These individuals and entities include former government officials of the former regime of Bashar al-Assad (including family members), his associates, human rights abusers, drug traffickers, persons linked to chemical weapons activities, ISIS or its affiliates, Iranian proxies, and others who may engage in the disruption or prevention of efforts to promote a stable Syria. The list of persons and entities added to the SDN List can be found here.
OFAC has also released Frequently Asked Questions 1220-1223 to provide guidance on continued reliance on OFAC Syria General License 25 and addressing other aspects of President Trump’s EO of June 30, 2025.
Suspension of Certain Statutory Sanctions under the Caesar Syria Civilian Protection Act
The EO directs the Secretary of State to examine whether certain criteria set forth in the Caesar Act have been met and evaluate suspending sanctions. This law, enacted in 2019, established mandatory sanctions to target foreign persons who facilitated the Assad regime’s acquisition of goods, services, or technologies that supported the regime’s military activities as well as its aviation and oil and gas production industries. If such criteria have been met, the Secretary of State may suspend the imposition of such sanctions, so long as continued review of the situation in Syria is undertaken to ensure that reimposition of any sanctions are not necessary.
Note that the Treasury and State Departments in May 2025 waived sanctions under the Caesar Act. See Thompson Hine Update of May 27, 2025. With the June 30, 2025 EO, the State Department has now formally terminated economic sanctions against various Syrian entities and, as previously noted, OFAC has removed such persons and entities from its SDN List. Thus, all property and interests in property of such designated persons that are in the United States or in possession or control of U.S. persons are unblocked. Additionally, all entities owned, either directly or indirectly, 50% or more by one or more blocked persons are also unblocked.
In a brief statement, Secretary of State Marco Rubio stated that he would now “examine the potential full suspension of the Caesar Act.”
Waiver of Export Controls under the Syria Accountability and Lebanese Sovereignty Restoration Act of 2003
The EO also waives and relaxes the application of certain export controls on items on the Commerce Control List and certain provisions of the Syria Accountability Act. President Trump has determined that it is in the national security interests of the United States to waive such restrictions and has directed the Secretary of State to submit to the appropriate Congressional committees the report and certification required by this Act.
This Act requires the President to implement two or more sanctions from a menu-based list and includes prohibiting the export of U.S. origin products (other than food and medicine) to Syria. It should be noted, however, that while the President has made the required determination that Syria meets the requirements for sanctions relief under the Syria Accountability Act, as of June 30, 2025, such a determination has not been certified to Congress. Thus, the lifting of the prohibition of exports to Syria of items on the Commerce Control List of dual-use items in the Export Administration Regulations (EAR), identifying which export controls will be relaxed, and establishing any continuing requirements to obtain necessary licenses from the Department of Commerce’s Bureau of Industry and Security (BIS) have not been implemented and these sanctions have not been immediately lifted.
Waiver of Sanctions under the Chemical Biological Weapons Control and Warfare Elimination (CBW) Act
The EO also waives various sanctions imposed on Syrian under the CBW Act due to the prior use of chemical weapons under the former regime of Bashar al-Assad. This includes the lifting of restrictions on foreign assistance; restrictions on U.S. government credit, credit guarantees, or other financial assistance; restrictions on the export of certain national security-sensitive goods and technology; and restrictions on U.S. banks from making loans or providing credit to the Government of Syria. Again, while the President has made the determination that Syria meets the requirements for sanctions relief under this Act, such a determination and a report must be transmitted to Congress. The EO states that these waivers to allow the resumption of financial aid will be effective 20 days after appropriate notice has been made to the Congress.
Other Actions
The EO also directs the Secretary of State to undertake all appropriate action with respect to the designation of certain Syrian persons and entities, including Hay’at Tahrir al-Sham’s (HTS), as “Specially Designated Global Terrorists” and to review the designation of Syria as a State Sponsor of Terrorism. The Secretary of State is also directed to take appropriate steps to advance U.S. policy objectives at the United Nations to support a Syria that is stable and at peace and to explore avenues at the United Nations to provide sanctions relief.
In a related Fact Sheet issued by the White House, it is noted that President Trump “is committed to supporting a Syria that is stable, unified, and at peace with itself and its neighbors.” However, the United States will seek to “reengage constructively,” thus the Trump Administration will continue “to guard against all threats and monitor progress on key priorities.”
Thompson Hine will continue to monitor the relaxation of sanctions and exports controls on Syria and report further developments as necessary.