President Trump has cracked down on terror support networks in Yemen and Iran, but he has also extended hope for development in war-torn Syria. Amid a wave of multibillion-dollar regional investment announcements, President Trump announced in Riyadh his intention to lift all sanctions on Syria “to give them a chance at greatness.” Ten days after President Trump’s speech, on May 23, 2025, the U.S. Office of Foreign Assets Control (“OFAC”) issued General License 25 (“GL 25”) lifting most sanctions on Syria and authorizing transactions linked to Syrian investment, including those involving certain blocked persons.
The U.S. Department of the Treasury in a press release stated that GL 25 “is intended to help rebuild Syria’s economy, financial sector, and infrastructure, in line with U.S. foreign policy interests. To do this, it is critical to bring new investment into Syria and support the new Government of Syria.”[1]
GL 25 Scope and Limitations
Prior to the issuance of GL 25, U.S. persons were prohibited from engaging in transactions linked to “new investment” in Syria, which was broadly defined as any contribution of funds or other assets and any extension of credit.[2] GL 25 generally authorizes transactions linked to Syrian investment, including transactions involving the new Syrian government.
The OFAC Fact Sheet published with GL 25 notes that it does not authorize any transaction involving any individual or entity on OFAC’s Specially Designated Nationals and Blocked Persons List (SDN List)—such as Bashar al-Assad, his enablers, and Captagon traffickers Taher al-Kayali and Khaldoun Hamieh—and any entity in which one or more of such SDNs own 50 percent or more, other than those listed in the Annex of GL 25. Many leading banks, energy companies, and even state-owned enterprises are included on the GL 25 Annex; prospective investors should review the list and conduct proper due diligence on ownership.
Complementing GL 25
Along with the announcement of GL 25, the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) provided relief under 31 U.S.C. § 5318(a)(7) and 31 C.F.R. § 1010.970 permitting covered financial institutions to open and maintain correspondent accounts for the Commercial Bank of Syria subject to certain conditions.
Likewise, the U.S. Department of State, pursuant to section 7432(b)(1) of the Caesar Syria Civilian Protection Act of 2019,[3] issued a 180-day waiver of the application of sanctions under Section 7412. As per this waiver, U.S. secondary sanctions will not be applied against non-U.S. parties operating under GL 25.
Syria Remains High-Risk
Syria remains a high-risk jurisdiction, and care should be taken to identify the counterparty to any transaction. GL 25 does not authorize transactions with blocked entities and individuals who do not appear in the Annex. Nor does it permit transactions for or on behalf of Russia, Iran, or North Korea, or that are related to the transfer or provision of goods, technology, software, funds, financing, or services to or from those countries.
EU and UK Sanctions
On May 20, 2025, the EU announced the lifting of sanctions on Syria. While no concrete steps have been taken, that may soon change. Earlier this year, on February 24, 2025, the EU suspended sanctions on Syria focused on certain sectors and extended exemptions for humanitarian purposes.
The UK HM Treasury’s Office of Financial Sanctions Implementation lifted sanctions on various Syrian entities on March 6 and again on April 24, 2025.
The recent U.S. decision to ease sanctions on Syria may prompt further announcements from the EU and the UK. All of this is consistent with a global effort to support the recovery of Syria.
How LBKM Can Help
Reconstructions efforts in Syria present exciting opportunities for businesses to play a role in the country’s transformation. LBKM has worked successfully on behalf of numerous persons and entities based in the Middle East, Southeast Asia, and Eastern Europe on a variety of U.S. sanctions issues, including advising multinational companies on sanctions compliance, obtaining the release of blocked funds, and convincing OFAC to remove sanctions on designated individuals. We have worked with semi-governmental bodies, NGOs, banks, corporations, political factions, corporate and bank officials, and high-level politically exposed persons.
If you have questions or concerns about the scope or reach of U.S. sanctions enforcement, please contact one of the professionals listed above to have a privileged and confidential discussion.
The foregoing is for informational purposes only. It is not intended as legal advice and no attorney-client relationship is formed by the provision of this information.
[1] https://home.treasury.gov/news/press-releases/sb0148.
[2] 31 C.F.R. § 542.315.
[3] 22 U.S.C. § 8791 note.
###
About LBKM
Lewis Baach Kaufmann Middlemiss PLLC is a boutique law firm focusing on international financial disputes, financial compliance, white collar defense and investigations, insurance and reinsurance, and cross-border commercial litigation and arbitration. The firm has offices in Washington, New York, and London.