Syria Sanctions Since the Fall of Assad: Updates from the United States and European Union
In the aftermath of the fall of Bashar al-Assad in early December 2024, the United States and the European Union have taken steps to ease sanctions and facilitate the provision of basic services in Syria. Even after these changes however, Syria remains one of the most comprehensively sanctioned countries in the world, with many, including the interim government, arguing for further sanctions relief.
Those who advocate for sanctions relief argue that leaving Assad-era sanctions in place raise due process concerns, as they were originally imposed in response to crimes committed by an authority no longer in power. They also contend that maintaining sanctions will make it difficult for the Syrian government to meet the basic needs of the population, risking further destabilization.
However, others argue that sanctions are a crucial tool for the international community to influence the new government and that they should not be completely lifted until a strong human rights record is established. Moreover, some states may be hesitant to lift sanctions prematurely given the technical and political challenges that often arise in their implementation. Once lifted, re-implementation may be difficult if the new government falters.
In response to these challenges, both the U.S and EU have taken an intermediate path. The U.S. has issued a new General License that allows for specific transactions, while the EU has tentatively agreed to a staged approach that involves lifting certain sectoral sanctions, with details yet to be publicly shared. Ultimately though, the changes to date are limited, and existing sanctions still hamper the ability of the new interim government to establish a functioning state. This article provides an overview of both U.S. and EU sanctions regimes, changes made since December 8, and recommendations on ensuring that a staged approach is effective.
The Sanctions Framework in the United States
The United States can impose sanctions via legislation passed by Congress or executive orders issued by the president that respond to national emergencies. The responsibility for enforcing sanctions then relies on various governmental departments, primarily the Treasury Department’s Office of Foreign Assets Control (OFAC).
U.S. sanctions against Syria began as early as 1979, when the U.S. designated Syria a State Sponsor of Terrorism. The U.S. developed a much more comprehensive sanctions regime against the Assad government after the outbreak of the Syrian conflict in 2011. These sanctions prohibit a broad array of activities, including the provision of U.S. government assistance to the Syrian government; trade in military supplies or dual use items (those that have both military and civilian purposes); export of U.S. goods or services to Syria; use of U.S. financial services in Syria; prohibition of the import of Syrian oil or related products to the U.S.; and the freeze of assets of Syrian government entities. In addition, a long list of individuals associated with the Syrian government or other parties to the conflict have been individually sanctioned. In 2019, sanctions were expanded under the Caesar Act to include third party entities engaged in business in Syria, with a focus on halting reconstruction efforts.
As an attempt to alleviate the unintended, civilian impact of these restrictions, the U.S. government has created pathways for humanitarian exemptions. Businesses can apply for a Specific License (SL), which allows them to undertake specific activities legally. Additionally, OFAC issues General Licenses (GL), which create exceptions for categories of activities, without the need to apply for an exemption.
However, these exemptions have faced challenges. The approval process for a SL is burdensome and lengthy, and in many cases banks still decline the relevant transaction. GLs often presented even more difficulties for actors as they provide banks with no specific assurances regarding the legality of a transaction related to Syria. In both cases, the fear of unintentionally violating sanctions law is so great that it has created a chilling effect, effectively blocking even those transactions that would be legal under current licenses.
Despite these challenges, OFAC issued another GL after the fall of Assad in December to ease some of the restrictions previously in place on transactions with Syria.
Updates to U.S. Sanctions Since the Fall of Bashar al-Assad
General License No. 24 (GL 24), issued by OFAC on January 6, 2025 and set to expire on July 7, 2025, introduced limited flexibility to U.S. sanctions policy towards Syria. Key provisions of GL 24 aim to guarantee that essential services — critical for the health, safety, and survival of Syria’s population — can be administered. The license includes:
- Authorizing transactions with Syrian governing institutions that provide essential public services, such as hospitals, schools, and utilities, at the federal, regional, or local levels;
- Permitting transactions related to energy supplies, including petroleum, natural gas, and electricity, for humanitarian purposes; and
- Allowing non-commercial personal remittances sent to individuals in Syria, including those processed through the Central Bank of Syria.
OFAC also clarified that transitional justice activities, including efforts to support the rule of law, human rights, and government accountability are broadly authorized under the general license. This includes activities carried out by international organizations and non-governmental organizations aimed at documenting atrocities, supporting legal reforms, and promoting long-term peacebuilding.
In addition to GL 24, the Biden Administration issued Executive Order 14142, which made changes to President Trump’s Executive Order 13894. The amended order continues to authorize the U.S. to sanction individuals directly or indirectly responsible or complicit in acts that threaten Syria’s security or territorial stability but removes the mention of Türkiye, whose mention was included in response to their launching Operation Peace Spring in 2019.
Even with these changes, most sectors and activities remain sanctioned by the United States. As the title of the license suggests, GL 24 is intended to ease restrictions only on transactions with governing institutions and specific transactions related to energy and personal remittances, leaving a myriad of other sectoral and financial sanctions in place – including export controls that prohibit the export of all U.S. items to Syria except for food and basic medicine. Moreover, the continued sanctions on the banking sector will greatly inhibit reconstruction efforts and continue to isolate Syria from the international financial system.
Further limiting the impact of GL 24 is the fact that HTS is still designated as a Foreign Terrorist Organization under U.S. law, creating uncertainty as to the nature of transactions that will be allowable with the current transitional government. Persons in the United States are barred from providing material support or resources to a Foreign Terrorist Organization (FTO). Terrorist designations are not impacted by licenses issued by OFAC, meaning engage with the interim government, as permitted by GL 24, still carries the legal risk of engaging with an FTO.
Overall, while the U.S. has taken steps to alleviate sanctions, the impact of these measures is quite limited in scope. While the U.S. government has stated its intention to monitor the evolving situation in Syria before lifting additional sanctions, the government has not provided clear and public guidance as to what conditions would merit the lifting of sanctions. For example, at a hearing held by the Senate Foreign Relations Committee on navigating Syria policy after Assad, Chairman and Senator Risch stated that additional sanctions should be lifted based on “how the new interim government acts.” Such conditions should be outlined by the national security council as they draft a new policy towards Syria.
The Sanctions Framework in the European Union
There are three ways the EU can adopt sanctions: transposing UN sanctions to EU law, reinforcing UN sanctions through the imposition of more restrictive measures, or autonomously imposing sanctions through its own regime. For all three options, the adoption process in the EU starts with a proposal by the High Representative of the Union for Foreign Affairs and Security Policy (High Representative), Kaja Kallas. The proposals must then be unanimously adopted by EU member states, barring certain exceptions.
While the U.S. has the most comprehensive sanctions policy towards Syria, the EU has maintained restrictive policies that are more targeted in their scope. After the outbreak of the Syrian conflict, the EU introduced sanctions against Syria in May 2011, which included an arms embargo, a visa and travel ban, and the freezing of assets of individuals responsible for the conflict. These sanctions were replaced and expanded in January 2012, when the Council of the EU published Resolution 36/2012 and introduced an arms embargo, restrictions on participation in infrastructure projects, restriction of entry of certain individuals, and a general freezing of funds of a range of individuals and entities associated with the Assad government. In 2013, these sanctions were again expanded when the Council of the EU introduced an oil embargo, trade restrictions, banking sanctions, and import sanctions that were recently renewed.
Alongside these sanctions existed the EU Global Human Rights Sanction regime, which was adopted in December 2020 and allowed the EU to target individuals, entities, and bodies – be they state or non-state actors – responsible for human rights violations regardless of where they occurred.
Prior to the implementation of these sanctions, the EU was Syria's largest trading partner and continued to be at least until 2020, meaning that EU sanctions had a particularly devastating effect on the Syrian economy, with formal trade collapsing and smuggling networks emerging to enrich the ruling party surrounding the Assad family.
Updates to European Union Sanctions since the Fall of Bashar al-Assad
Since the fall of the Assad government, member states have pressured the EU to move towards a progressive lifting of sanctions, which requires a unanimous decision. On 24 February 2025, following a ministerial meeting of the Council of the EU, the European Union decided to lift sanctions on the energy and transport sectors, introduce certain exemptions to the prohibition of establishing banking relations between Syrian banks and financial institutions within the territories of the member states, to allow transactions associated to the energy and transport sectors as well as transactions needed for humanitarian and reconstruction purposes, introduce an exemption for personal use to export prohibitions of luxury goods to Syria and remove 5 financial institutions from the list of those subject to the freezing of funds and economic resources, as well as to allow making funds and economic resources available to the Syrian Central bank. Sanctions linked to the Al Assad family, chemical weapons and drug trade have been kept, and more changes are subjected to close inspection by the EU.
Unclear Conditions Going Forward
Remaining sanctions, as well as the unintended freezing effect they have on legal activities, continue to significantly hamper the ability of the interim government to function. If the government is to meet the expectations of the international community, including protecting human rights and pursuing justice and accountability, it will need the resources to establish functioning government institutions. While keeping certain sanctions in place as a tool for behavior change is reasonable, the U.S. and the EU should immediately provide broader relief, including by lifting or providing waivers for sanctions on financial institutions and the energy sector.
Both the U.S. and EU have indicated that the lifting of sanctions is conditional on the current government’s behavior. However, sanctions will only be effective in influencing the behavior of the interim government if it is made clear what behavioral changes are required. Going forward, the U.S. and EU should make public explicit benchmarks, including regarding the respect of human rights and the implementation of transitional justice processes, necessary for the continued lifting of sanctions.
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