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 Syria General License No. 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. The 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.”

II. United States Sanctions Programs

GL 24 must be read within the context of sanctions that have been imposed on Syria since 1979 and on existing authorizations in the Syrian Sanctions Regulations, Global Terrorist Sanctions Regulations and Foreign Terrorist Organization Sanctions Regulations, including those that support the activities of NGOs, international organizations and humanitarian and stabilization efforts in the region. A summary of these sanctions programs is provided below.

State Sponsor of Terrorism

Syria has been designated a State Sponsor of Terrorism since 1979. As such, it is subject to Section 1754(c) of the National Defense Authorization Act for Fiscal Year 2019, Section 40 of the Arms Export Control Act and Section 620A of the Foreign Assistance Act of 1961. The four main categories of sanctions resulting from designation under these authorities include restrictions on U.S. foreign assistance; a ban on defense exports and sales; certain controls over exports of dual use items; and miscellaneous financial and other restrictions.

GL 24 does not remove any of these restrictions.

Syrian Sanctions Regulations

Syria is subject to a comprehensive embargo. Comprehensive embargoes are the most restrictive sanctions imposed by the United States.

The current Syrian Sanctions program began with the issuance of Executive Order (E.O.) 13338 by President George W. Bush on May 11, 2004. This act authorizes the President to impose economic sanctions against foreign nations following a declaration of a national emergency due to an “unusual and extraordinary threat” to U.S. national security and foreign policy. Subsequently, President Bush issued E.O.s 13399 and 13460, both of which authorized the blocking of property of persons in connection with the national emergency declared with respect to Syria.

President Barack Obama subsequently issued several additional E.O.s including: E.O. 13572, which authorized the blocking of property of certain persons involved in human rights abuses in Syria; E.O. 13573, which authorized the blocking of property of senior Syrian government officials; E.O. 13582, which blocked property of the Government of Syria and prohibited certain transactions with Syria; and E.O. 13606, which authorized the blocking of property and suspended entry into the United States for certain individuals involved in grave human rights abuses in Syria and Iran via information technology. These E.O.s were subsequently formalized in the Syrian Sanctions Regulations, 31 C.F.R. part 542 (“SySR”).

The Government of Syria, including its political subdivisions, agencies and instrumentalities, has been blocked. As a consequence, U.S. financial institutions and other U.S. persons are prohibited from transacting with these entities. Any property of a blocked person that comes into the possession or control of a U.S. person or comes into the U.S. cannot be transferred, paid, exported, withdrawn or otherwise dealt with. In addition, a U.S. person cannot make any contribution, provision of funds, goods or services to a blocked person.

Syria-Related Sanctions under E.O. 13894 of 2019

The Syria-Related Sanctions were issued in 2019 in response to actions by the Government of Turkey to conduct a military offensive in northeast Syria. The sanctions, codified under the Syria-Related Sanctions Regulations, 31 C.F.R. Part 569, block all property and interests in property that are in the U.S., that come within the U.S., or that are or come within the possession or control of any U.S. person of any person determined by the Secretary of the Treasury to be responsible for or complicit in actions or policies that further threaten the peace, security, stability, or territorial integrity of Syria or the commission of serious human rights abuse, among other classes of persons outlined under Section 1(a)(i). As in the case of the Syria Sanctions program, any entity that is directly or indirectly owned 50% or more by a specially designated national (“SDN”) is itself also considered an SDN, even if not directly listed.

Caesar Syria Civilian Protection Act of 2019

The Caesar Syria Civilian Protection Act of 2019, established under Sections 7404-7438 of the National Defense Authorization Act for Fiscal Year 2020, Title LXXIV, created additional sanctions and financial restrictions on institutions and individuals related to the conflict in Syria. It contains secondary sanctions on non-U.S. entities that facilitate transactions with the Government of Syria. Under the Caesar Act, OFAC or the State Department are required to impose sanctions on a foreign person if it is determined that the foreign person:

(A) knowingly provides significant financial, material, or technological support to, or knowingly engages in a significant transaction with—

(i) the Government of Syria (including any entity owned or controlled by the Government of Syria)…

(iii) a foreign person subject to sanctions…with respect to Syria…

The Caesar Act was extended until December 31, 2029 by Public Law No. 118-159, National Defense Authorization Act for Fiscal Year 2025, signed into law by President Biden on December 23, 2024.

While only Congress can permanently lift the Caesar Act, the President can temporarily suspend Caesar Act sanctions pursuant to Section 7431. On February 15, 2025, U.S. Senator Jim Risch (R-Idaho), chairman of the Senate Foreign Relations Committee, proposed five conditions for lifting Caesar Act sanctions: (1) evidence that the interim government will not allow Syria to be a launching pad for terror attacks against the United States or its partners, including full accountability and elimination of the Assad regime’s chemical weapon stockpiles, (2) permanent ejection of Russia and Iran from Syria, (3) ending Syria’s methamphetamine trade, (4) accountability for American citizens detained by the Assad regime, including Austin Tice, and (5) a political roadmap that “returns power to the Syrian people.”

Other Syrian Sanctions Programs

In addition, multiple other E.O.s block persons responsible for grave human rights abuses in Syria and prohibit transactions with sanctions evaders with respect to Syria. Examples include E.O. 13606 of April 22, 2012, Blocking Persons With Respect to Grave Human Rights Abuses by the Governments of Iran and Syria Via Information Technology, and E.O. 13608 of May 1, 2012, Prohibiting Certain Transactions With Foreign Sanctions Evaders With Respect to Iran and Syria. Syrian individuals and entities may also be listed as SDNs under sanctions programs that are applicable worldwide under thematic E.O.s, including those concerning proliferation of weapons of mass destruction, terrorism, narcotics or violation of human rights. These sanctions programs include the Global Terrorism Sanctions Regulations, the Weapons of Mass Destruction Proliferators Sanctions Regulations and the Transnational Criminal Organizations Sanctions Regulations.

III. General License 24 of 2025

Overview

On January 6, 2025, OFAC issued GL 24 to expand authorizations for activities and transactions in Syria. According to OFAC’s press release, this action underscores the United States’ commitment to ensuring that U.S. sanctions do not impede activities to meet basic human needs, including the provision of public services or humanitarian assistance. The authorizations of GL 24 are valid for six months, as the U.S. government continues to monitor the evolving situation in Syria.

Despite prohibitions under the SySR, the Global Terrorism Sanctions Regulations, 31 C.F.R. part 594 (“GTSR”), and the Foreign Terrorist Organizations Sanctions Regulations, 31 C.F.R. part 597 (“FTOSR”), 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).

Definition of “Governing Institutions”

OFAC 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.”[24] 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.”

Interaction with E.O. 13582 of 2011, Blocking Property of the Government of Syria and Prohibiting Certain Transactions with Respect to Syria

While authorizing transactions with governing institutions in Syria, GL 24 states that financial transfers to any person blocked pursuant to the GTSR, the FTOSR or the SySR are not permitted, other than for the purpose of effecting:

• The payment to governing institutions in Syria of taxes, fees, or import duties,
• 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
• The purchase or receipt of permits, licenses, public utility services, or other public services in Syria

Therefore, with some very narrow exceptions, financial transfers to any person blocked under the SySR, including the Government of Syria, remain prohibited.

However, GL 24 opens a new door to certain transactions with blocked Syrian governing institutions that were previously prohibited under the SySR. Prior to the issuance of GL 24, transactions with blocked Government of Syria persons were generally prohibited. GL 24 now allows certain transactions with the governing institutions in Syria, including persons blocked pursuant to the GTSR, FTOSR or SySR. However, financial transfers to such blocked persons remain prohibited. As an exception to this, financial transfers to blocked governing institutions in Syria are permitted if they are “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 the Office of Foreign Assets Control’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.”

Concretely, this means that transactions other than those that involve financial transfers to blocked Syrian governing institutions, including transactions that involve a receipt of a financial transfer from a blocked Syrian governing institution and transactions involving a barter with such institutions, are now permitted throughout the period of validity of GL 24, whereas they were previously prohibited. However, the Material Support Statute remains in effect and the Department of Justice has not made any assurances that it will not prosecute dealings with HTS as “material support for terrorism” under 18 U.S.C. § 2339B.

The authorization in GL 24 may overlap with existing GLs issued under the SySR, the GTSR and the FTOSR, including: transactions in support of certain nongovernmental organizations’ activities; official business of the U.S. Government; official business of certain international organizations; and activities in certain economic sectors in specified areas of northeast and northwest Syria.

IV. Conclusion

Whether GL 24 is extended 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 GL 24. 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 Syria sanctions will continue to be eased.