U.S. Treasury Issues Sanctions Relief Following Regime Change in Syria

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I. Introduction

In an effort to facilitate the provision of public services, the continuity of governance and humanitarian assistance in Syria, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued General License 24 (GL 24) on January 6, 2025. GL 24 expands authorizations for activities and transactions in Syria following the end of Bashar Al-Assad’s rule on December 8, 2024. It authorizes a range of transactions with the transitional Syrian government, eases restrictions on transactions in support of the sale, supply, storage, or donation of energy to or within Syria and permits transactions that are ordinarily incident and necessary to processing the transfer of personal remittances. Deputy Secretary of the Treasury Wally Adeyemo announced that during this period of transition, the U.S. Treasury will “continue to support humanitarian assistance and responsible governance in Syria.”

GL 24, which is currently set to expire on July 7, 2025, may be extended as the U.S. government continues to monitor the evolving situation on the ground in Syria. OFAC’s announcement highlights that “Syria is one of OFAC’s most comprehensively sanctioned jurisdictions” as a result of human rights abuses committed by the former regime as well as “support for terrorism, and destabilizing actions across the region.” Following a monitoring period of six months, the U.S. government may decide to extend the term of GL 24.

II. United States Sanctions Programs

GL 24 must be read within the context of sanctions that have been imposed on Syria since 1979 and existing authorizations in the Syrian Sanctions Regulations, 31 C.F.R. part 542 (SySR). In addition, GL 24 must be read within the context of the Syria-Related Sanctions, codified under the Syria-Related Sanctions Regulations, 31 C.F.R. Part 569, which were issued in 2019, as well as the Global Terrorism Sanctions Regulations, 31 C.F.R. part 594 and the Foreign Terrorist Organizations Sanctions Regulations, 31 C.F.R. part 597.

Syria has been designated a State Sponsor of Terrorism since 1979, resulting in restrictions on U.S. foreign assistance, a ban on defense exports and sales, certain controls over exports of dual use items and miscellaneous financial restrictions. GL 24 does not remove any of these restrictions.

III. General License 24

Section (a) of GL 24 authorizes the following transactions through July 7, 2025:

(1) Transactions with governing institutions in Syria following December 8, 2024;

(2) 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

(3) Transactions that are ordinarily incident and necessary to processing the transfer of noncommercial, personal remittances to Syria, including through the Central Bank of Syria.

Separately, Section (b) explicitly states that the following transactions are not authorized by the General License:

(1) The unblocking of any property blocked pursuant to any part of 31 C.F.R. Chapter V;

(2) Any transactions involving military or intelligence entities or any persons acting for or on behalf of such entities;

(3) Transactions prohibited by 31 CFR § 542.208 (the importation into the U.S. of petroleum or petroleum products of Syrian origin);

(4) Any transactions for or on behalf of the Government of the Russian Federation or the Government of Iran or related to the transfer of Iranian-origin or Russian-origin goods, technology, software, funds, financing or services;

(5) Financial transfers to any person blocked pursuant to the Global Terrorism Sanctions Regulation, the Foreign Terrorist Organizations Sanctions Regulations or the SySR other than for the purpose of effecting:

(i) The payment to governing institutions in Syria of taxes, fees, or import duties,

(ii) The payment of salaries or wages of Syrian governing institution employees who are not identified on OFAC’s List of Specially Designated Nationals and Blocked Persons, or

(iii) The purchase or receipt of permits, licenses, public utility services, or other public services in Syria; or

(6) Transactions prohibited by 31 CFR § 542.206 (new investment in Syria), except for contributions of funds for salaries or wages of employees of governing institutions in Syria consistent with subparagraph (b)(5).

Office of Foreign Assets Control FAQ 1206 states that “Syrian governing institutions include 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.” FAQ 1207 gives some examples of authorized transactions, which include “providing services to, or paying for services received from, Syrian governing institutions, such as the Ministry of Health, the Ministry of Education, or the Ministry of Water Resources, even if the ministry or leadership of the institution is blocked.” Payments made to Syrian governing institutions outside of the narrow confines provided by GL 24 (b)(5) remain prohibited.

IV. Extension of the Exemption

Whether GL 24 is extended beyond July 7, 2025 will likely depend on a series of factors. These factors may include the extent to which the Syrian transitional government stabilizes the situation in Syria, commits to uphold human rights, combats terrorism, ejects foreign fighters from Syrian territory and commits to democratic governance that returns power to the Syria people. However, the U.S. government has not yet publicly stated the conditions for extending the general license. As the U.S. government continues to monitor the situation on the ground in Syria, it is possible that additional exemptions will be issued and Syrian sanctions will continue to be eased.