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Syrian Market Now Open (Partially) to US Businesses and Persons

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Syria sanctions have been lifted and export controls have been substantially relaxed,&nbsp;but

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Many entities and individuals previously sanctioned under the Syria program remain sanctioned under the new PAARSS program; and

License requirements remain in place for most exports to Syria of commodities, software or technology, including for EAR99 items other than food and medicine and deemed exports and deemed reexports of EAR99 technology, although license exceptions may be available.

Caution should be exercised by U.S. persons and businesses doing business with persons in Syria to ensure compliance with the remaining sanctions and export controls.

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As of September 2, 2025, for the first time in more than two decades, the Syrian market has opened significantly for U.S. businesses and U.S. persons. The market opened through the lifting of U.S. sanctions and certain export controls, specifically, the U.S. Department of the Treasury’s Office of Foreign Assets Controls’ (OFAC) comprehensive economic sanctions on Syria and the U.S. Department of Commerce, Bureau of Industry and Security’s (BIS) Export Administration Regulations (EAR). These regulatory changes implemented by President Donald Trump’s June 30, 2025 <a href="https://www.federalregister.gov/documents/2025/07/03/2025-12506/providing-for-the-revocation-of-syria-sanctions" target="_blank" rel="noreferrer noopener">Executive Order 14312</a>, “Providing for the Revocation of Syria Sanctions” (the EO).

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As discussed herein, while sanctions have been lifted and export controls have been relaxed, sanctions remain on malign actors, including Bashar al-Assad and his associates, human rights abusers, drug traffickers, persons linked to Syria’s past proliferation activities, ISIS and Al-Qa’ida affiliates, and Iran and its proxies. Further, most technology, commodities and software (collectively, Items) still require a license to be sent to Syria. Thus, U.S. entities and individuals, as well as foreign persons dealing in U.S.-origin Items and other Items subject to U.S. export controls, must be diligent in engaging in any business with Syria to ensure compliance with the remaining U.S. sanctions and export controls.

On June 30, 2025, the President issued <a href="https://ofac.treasury.gov/media/934411/download?inline" target="_blank" rel="noreferrer noopener">EO 14312</a> revoking the executive orders that implemented most of the prior Syria economic sanctions and terminating the national emergency declared in 2004 as to Syria.

Pursuant to <a href="https://ofac.treasury.gov/media/934411/download?inline" target="_blank" rel="noreferrer noopener">EO 14312</a>, which was effective July 1, 2025, the comprehensive U.S. economic sanctions against Syria were terminated and the sanctions transitioned into the <a href="https://ofac.treasury.gov/sanctions-programs-and-country-information/paarss" target="_blank" rel="noreferrer noopener">Promoting Accountability for Assad and Regional Stabilization Sanctions (PAARSS)</a> program.

Further, more than 500 individuals and entities designated solely pursuant to the revoked executive orders were removed from OFAC’s Specially Designated Nationals and Blocked Persons (SDN) List pursuant to EO 14312 (see June 30, 2025 <a href="https://www.whitehouse.gov/fact-sheets/2025/06/fact-sheet-president-donald-j-trump-provides-for-the-revocation-of-syria-sanctions/" target="_blank" rel="noreferrer noopener">White House Fact Sheet</a> and <a href="https://www.state.gov/releases/office-of-the-spokesperson/2025/06/termination-of-syria-sanctions/" target="_blank" rel="noreferrer noopener">U.S. Department of State Fact Sheet</a>).

Also, EO 14312 amended <a href="https://www.federalregister.gov/documents/2019/10/17/2019-22849/blocking-property-and-suspending-entry-of-certain-persons-contributing-to-the-situation-in-syria" target="_blank" rel="noreferrer noopener">EO 13894 of 2019 to</a> maintain sanctions on Syria’s former leader, Bashar al-Assad, and other destabilizing regional actors (see <a href="https://home.treasury.gov/news/press-releases/sb0183" target="_blank" rel="noreferrer noopener">U.S. Department of the Treasury Press Release</a>).

<a href="https://www.federalregister.gov/documents/2025/08/26/2025-16324/syrian-sanctions-regulations" target="_blank" rel="noreferrer noopener">Effective Aug. 26, 2025,</a> the Syria Sanctions Regulations were removed from the Code of Federal Regulations.

<a href="https://www.federalregister.gov/documents/2025/09/02/2025-16724/relaxing-export-controls-for-syria" target="_blank" rel="noreferrer noopener">Effective Sept. 2, 2025</a>, certain EAR controls relating to Syria were relaxed. However, as in the past, only food and medicine classified as EAR99 and deemed exports and reexports of EAR99 technology to Syrian nationals do not require a license to go to Syria under the EAR.

While most Items still require an EAR license to go to Syria, the EAR license exceptions were expanded to authorize a wide variety of exports and reexports to Syria, including U.S.-origin Items classified as EAR99 and consumer communications devices as well as certain civil aviation Items.

Also, the EAR’s licensing policy for dual-use Items going to Syria is now applied on a case-by-case basis, with a presumption of approval for Items supporting Syrian people and Syrian economic development.

As mentioned above, <a href="https://home.treasury.gov/news/press-releases/sb0183" target="_blank" rel="noreferrer noopener">effective July 1, 2025</a>, the comprehensive U.S. economic sanctions against Syria were terminated and the sanctions transitioned into a new, much-more-limited sanctions program, the <a href="https://ofac.treasury.gov/sanctions-programs-and-country-information/paarss" target="_blank" rel="noreferrer noopener">PAARSS</a> program. The PAARSS program targets Bashar al-Assad and his associates, human rights abusers, drug traffickers, persons linked to Syria’s past proliferation activities, ISIS and Al-Qa’ida affiliates, and Iran and its proxies. Specifically, EO 14312 maintained sanctions on Bashar al-Assad and certain other destabilizing regional actors and expanded the scope of the national emergency declared in&nbsp;<a href="https://ofac.treasury.gov/media/25986/download?inline" target="_blank" rel="noreferrer noopener">EO 13894</a>&nbsp;by sanctioning persons (and entities owned or controlled by them or acting on their behalf) that threaten the peace, security or stability of Syria; have committed serious human rights abuses in relation to Syria; are a former government official of the former regime of Bashar al-Assad or acted on behalf of such officials; are Captagon drug traffickers; have been involved in kidnapping and other disappearances of U.S. nationals or permanent resident aliens, and have adult family members of persons designated under certain sections of the executive order. EO 14312 further amended EO 13894 by directing OFAC to sanction any person found to have materially assisted, sponsored or provided financial, material or technological support for or goods or services in support of the aforementioned activities or to the former regime of Bashar al-Assad or activities sanctionable under the amended executive order (or persons blocked under the executive order whose assistance was already sanctionable under EO 13894).

OFAC also issued four new <a href="https://ofac.treasury.gov/faqs/added/2025-06-30">FAQs</a> clarifying the following:

“The United States no longer maintains comprehensive sanctions on Syria, effective July 1, 2025” (FAQs 1221), and that “all property and interests in property of [persons removed from the SDN List] are unblocked” (FAQ 1220).

Sanctions remain on “Bashar al-Assad and certain other destabilizing regional actors” (FAQ 1220).

U.S. financial institutions may “[establish] correspondent banking relationships with Syrian financial institutions,” and all Syrian financial institutions, including the Central Bank of Syria, have been removed from the SDN List (FAQ 1221).

To the extent necessary, persons may continue to use <a href="https://ofac.treasury.gov/media/934306/download?inline" target="_blank" rel="noreferrer noopener">GL 25</a> for specific activities under OFAC sanctions programs listed in GL 25 (FAQ 1223).

Effective September 2, 2025, the <a href="https://www.federalregister.gov/documents/2025/09/02/2025-16724/relaxing-export-controls-for-syria" target="_blank" rel="noreferrer noopener">EAR were amended</a> to relax export control requirements relating to Syria by expanding the use of license exceptions to authorize exports of EAR99 Items and certain anti-terrorism-only controlled Items. As stated above, all Items subject to the EAR other than food and medicine classified as EAR99 and deemed exports and reexports of EAR99 technology to Syrian nationals require a license to go to Syria. Thus, if an EAR license exception does not apply, then a license from BIS will need to be obtained prior to proceeding with the transaction. Key license exception changes include:

<a href="https://www.ecfr.gov/current/title-15/subtitle-B/chapter-VII/subchapter-C/part-740/section-740.5" target="_blank" rel="noreferrer noopener">New License Exception SPP</a> (Syria Peace and Prosperity),which authorizes exports and reexports of EAR99 Items except those subject to specific end-use or end-user controls or OFAC license requirements.

<a href="https://www.ecfr.gov/current/title-15/subtitle-B/chapter-VII/subchapter-C/part-740/section-740.19" target="_blank" rel="noreferrer noopener">Expansion of License Exception CCD</a> (Consumer Communications Devices) to include Syria as an eligible destination for consumer communications devices, subject to end-use and end-user controls.

<a href="https://www.ecfr.gov/current/title-15/subtitle-B/chapter-VII/subchapter-C/part-740/section-740.15" target="_blank" rel="noreferrer noopener">Revision of License Exception AVS</a> (Aircraft, Vessels and Spacecraft) to authorize for export or reexport to Syria EAR99 Items and Items controlled only for anti-terrorism reasons.

Expansion of available License Exceptions: The previous limitations on the use of license exceptions TMP (Temporary Imports, Exports and Reexports); RPL (Servicing and Replacement of Parts and Equipment); GOV (Government); TSU (Technology and Software Unrestricted); and BAG (Baggage) as to Syria have been removed. These license exceptions are now available for export and reexports to Syria when all the applicable criteria are met.

Further, the licensing policy for exports and reexports of Items on the Commerce Control List to Syria was relaxed to a presumption of approval for certain commercial end uses that support economic and business development in Syria and the Syrian people. The end uses subject to a presumption of approval include telecommunications infrastructure, sanitation, power generation and civil aviation. BIS will approve or reject license applications for other end uses on a case-by-case basis.

Consistent with the OFAC sanctions, BIS will continue to restrict exports and reexports involving malign actors or military end uses or military end users. Malign actors include Bashar al-Assad and his associates, human rights abusers, and persons designated under the PAARSS program.

With these latest changes, new opportunities have arisen for U.S. businesses and individuals to conduct business in Syria. However, these business opportunities will still require the proper level of due diligence to ensure compliance with remaining sanctions and export controls restrictions. Please do not hesitate to reach out to any member of our&nbsp;<a href="https://www.bakerlaw.com/International-Trade-National-Security" target="_blank" rel="noreferrer noopener">International Trade and National Security team</a>&nbsp;or your BakerHostetler relationship partner if you have questions.

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