The Office of Foreign Assets Control (OFAC) issued a Final Rule effective September 25, 2025 amending the Syria-Related Sanctions Regulations at 31 C.F.R. Part 569.  The heading of these regulations is being changed to the “Promoting Accountability for Assad and Regional Stabilization Sanctions Regulations.”  These amended regulations further implement Syria-related Executive Order 14312 (June 30, 2025). While earlier actions by President Donald Trump resulted in the removal of Syria sanctions regulations codified at 31 C.F.R. Part 542, OFAC made clear that certain sanctions would remain in place “against perpetrators of war crimes and 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, these amended regulations under Part 569 are focused on continuing sanctions on such persons and/or entities.

Mainly, the amended regulations update Executive Order citations and add EO 13894 as an appendix to the regulations.  OFAC notes that these amended regulations “remain in abbreviated form at this time for the purpose of providing immediate guidance to the public,” and that they will be further supplemented with a more comprehensive set of regulations, which may include additional interpretive guidance and definitions, general licenses, and other regulatory provisions.

For additional background on OFAC’s changes to its Syria sanctions regulations since the removal of Bashar al-Assad from power, see Thompson Hine Updated dated January 9, 2025, May 27, 2025, June 30, 2025, and August 27, 2025

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Photo of Scott E. Diamond** Scott E. Diamond**

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor…

Scott is a senior policy advisor with more than 25 years’ experience with the legislative and regulatory processes involved in international trade policy, remedies and enforcement. This includes working with clients on matters involving export controls, economic sanctions, human rights and forced labor compliance, corporate anti-boycott and antibribery compliance, national security investigations, and foreign direct investment in the United States.

**Not licensed to practice law.

Photo of Francesca M.S. Guerrero Francesca M.S. Guerrero

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some…

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.

Photo of Samir D. Varma Samir D. Varma

Samir advises multinational corporations on export controls, economic sanctions and customs, and counsels individuals and corporations on the Foreign Corrupt Practices Act (FCPA) and other anti-corruption laws. He represents clients in enforcement actions before U.S. regulatory agencies and conducts corporate internal investigations.

Photo of Aaron C. Mandelbaum Aaron C. Mandelbaum

Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade…

Aaron focuses his practice on advising clients on compliance with international economic sanctions, export controls, and U.S. import laws and regulations. He is also involved in assisting clients with complex cross-border transactions, anti-dumping and countervailing duty litigation, utilization of international and preferential trade agreements, and customs classifications. Most recently, Aaron has counseled clients navigating requirements under the Export Administration Regulations.